Apprenticeships Levy Consultation response form

Transcription

1 Apprenticeships Levy Consultation response form The department may, in accordance with the Code of Practice on Access to Government Information, make available, on public request, individual responses. The closing date for this consultation is 2 October You can also reply to this consultation online at: Please return completed forms to: apprenticeshipslevyconsultation@bis.gsi.gov.uk or: Apprenticeships Levy Consultation Department for Business, Innovation and Skills Spur 2 Level 2 1 Victoria Street London SW1H 0ET

2 What is your name? Janet Clark What is your address? What is your job title? Education policy Adviser When responding please state whether you are responding as an individual or representing the views of an organisation. I am responding as an individual I am responding on behalf of an organisation If you are responding on behalf of an organisation, please make it clear who the organisation represents by selecting the appropriate interest group on the consultation form and, where applicable, how the views of members were assembled.

3 What is the name of your organisation? Association of Teachers and Lecturers Business representative organisation/trade body Central government Charity or social enterprise Individual Employer (over 250 staff) Employer (50 to 250 staff) Employer (10 to 49 staff) Employer (up to 9 staff) Legal representative Local Government X Trade union or staff association Further Education college Private training provider University Professional body Awarding organisation Other (please describe) Where are you based? England Wales Scotland Northern Ireland UK wide

4 If you are responding as an employer, which sector of the economy are you in? Agriculture, forestry & fishing Energy & water Manufacturing Construction Distribution, hotels & restaurants Transport & communication Banking, finance & insurance etc X Public admin, education & health Other services

5 Consultation questions Paying the levy 1. Should a proportion of the apprenticeship funding raised from larger companies be used to support apprenticeship training by smaller companies that have not paid the levy? Yes No Only the large employers who pay the apprenticeship levy should receive funding from the apprenticeship levy fund. The Skills Funding Agency (SFA) should continue to fund apprenticeships for SMEs, with matched funding from SMEs. If smaller companies access the apprenticeship levy fund, there is a risk that there will be insufficient funding available for larger employers to get more back than they put in and take on more apprentices. It is however, important to ensure that the system of apprenticeship funding is fair; it should not result in smaller employers paying more per apprentice than larger companies, as this will result in a reduction in the availability of apprenticeships in SMEs. 2. Do you have any comments on the proposed mechanism for collecting the levy via PAYE? Yes No Collecting the apprenticeship via PAYE seems a sensible approach. We are concerned however, that a very costly and complex IT system will be required to collect and distribute the apprenticeship levy fund. There is risk that this will not be designed, built and tested by Furthermore, the cost of this should be borne by government, and not be funded by the proceeds raised by the apprenticeship levy. 3. In your opinion, how should the size of firm paying the levy be calculated?

6 The definition of large employer needs careful consideration to ensure that there can be no avoidance of paying the levy through, for example employing staff on zero or low hours contracts or through complex company structures. Whilst ATL believes that the numbers of employees on payroll, rather than full-time equivalent, should be used as the determinant of large employers, this raises a number of issues for the education sector. We are seeing the effects on the cut in school budgets in real terms. Similarly, further education budgets have been cut by 35% over the past five years, and are now facing a 24% reduction in adult learning from September this year. Schools and colleges will find it extremely challenging to bear the additional financial liability of an apprenticeship levy. Government needs to ensure that the education of children and young people is not negatively impacted as a result of the financial implications of the apprenticeship levy on schools and colleges.

7 4. Should employers be able to spend their apprenticeship funding on training for apprentices that are not their employees? Yes No We believe that this would complicate the system. For example, it could result in a situation where some employers benefit from apprenticeship funding from another company higher up the supply chain, and therefore receive much more than they paid into the apprenticeship levy. In addition, such a system may result in large employers supplementing SFA funded apprenticeships in SMEs. SFA funding should be ringfenced to fund those apprenticeships which are not funded by the large employer levy. Only allowing employers to spend their apprenticeship funding on apprentices employed by their company will also ensure that they retain responsibility for recruiting apprentices and the quality of their education and training. Employers operating across the UK 5. How should the England operations of employers operating across the UK be identified? No comment Allowing employers to get back more than they put in 6. How long should employers have to use their levy funding before it expires? 1 year 2 years Other (please state in comments below)

8 Many high quality apprenticeships last for longer than one year and some employers will not need to take these on annually. In addition, we are concerned that expiration of the levy funding after one year will result in poor quality, cheap apprenticeship programmes on roll-on roll-off one year contracts. Employers in the retail, care and hospitality sectors may be particularly keen to take on apprentices on this basis, in order to achieve the target necessary to recoup the levy. These apprenticeships will not result in high quality training for the learner, or employment at the end of apprenticeship. This will, in turn, damage the apprenticeship brand. 7. Do you have any other view on how this part of the system should work? Employers should be required to meet targets for conversion of apprentices into permanent employment in order to get back more than they put in. 8. Do you agree that there should be a limit on the amount that individual employer s voucher accounts can be topped up? Yes No Otherwise there is a risk that the surplus from the apprenticeship levy will not be sufficient to enable employers to get back more than they put in, particularly those who are not be geared up to recruit apprentices immediately. In addition, unlimited top-ups will encourage the low quality roll-on roll-off type programmes described above. Any surplus after employees have been allocated their apprenticeship levy funding, and taking into consideration any time limit which is set, should be ring-fenced to ensure that it is invested in the development and marketing of apprenticeships. This is particularly important to ensure adequate investment in future apprenticeships in new technologies. 9. How do you think this limit should be calculated?

9 This will need to be calculated on a sector-by-sector basis as the costs of apprenticeship will vary depending on the sector. The calculation should be simple and transparent. 10. What should we do to support employers who want to take on more apprentices than their levy funding plus any top ups will pay for? Employers wanting to take on more apprentices than those paid for by the levy, should fund these themselves. The levy is fair 11. How can we sure that the levy supports the development of high-quality apprenticeship provision?

10 A National Levy Board should be created to ensure that levy funding is not misused and that employers are committed to high quality provision when they access these funds. We are concerned that the proliferation of trailblazer apprenticeships has resulted in a lack of standardisation of provision and quality of programmes at the same level. Sector boards should therefore be established, with the expertise to set standards in individual sectors. When constituting the membership of these boards, lessons must be learned from the evaluation of trailblazer apprenticeships: 0/bis evaluation-of-the-apprenticeship-trailblazers-interim-report.pdf It is clear that there is a need to engage all stakeholders, with a range of expertise, to ensure quality of apprenticeship provision, and not just a small number of large employers. Trade unions should be represented on the National Levy Boards and the sector boards. In addition, apprentices should be represented on all of these boards, to ensure that the needs of the learner are considered and re-balance the focus on employer engagement. Fair pay should be an indicator of a good quality apprenticeship, as should the expectation of permanent employment on completion; apprenticeships should be real jobs. Training plans should be used to plan and agree high quality apprenticeships. Apprenticeship levy funding should not be released to employers until a training plan has been agreed and signed by the employer, training provider and apprentice. Trade unions should also sign off the training plan, which would be sent to the relevant sector board for approval so that funding can be released to the employer. The training plan would set out the standards, what would be included in the apprenticeship programme, and highlight the rights and responsibilities of each stakeholder. The government should use the CITB Deed as a model of good practice to ensure high quality apprenticeships. 12. How should these ceilings be set, and reviewed over time?

11 There must be controls to ensure that levy funding is not used fraudulently. Sector boards should determine and review the relevant rates for apprenticeships in each sector. 13. How best can we engage employers in the creation and wider operation of the apprenticeship levy? There should be a large marketing campaign which presents the apprenticeship levy as an opportunity for employers. Unions are well placed to play an important role in engaging employers in this area. Giving employers real control 14. Does the potential model enable employers to easily and simply access their funding for apprenticeship training? Yes No The proposal looks sensible subject to their being an IT system in place to deliver the model. However, more needs to be done to ensure that levy funding is only made available to those employers who are able to demonstrate a commitment to delivering high quality apprenticeships. This will require a governance model based on the National Levy Board and sectoral boards described above. 15. Should we maintain the arrangement of having lead providers or should employers have the option to work directly with multiple providers and take this lead role themselves if they choose to do so? Yes No

12 Lead providers should be accountable to the government for eligibility, quality and funding for the apprenticeship. This system results in less likelihood of rogue operators claiming apprenticeship levy funding. 16. If employers take on the lead role themselves what checks should we build in to the system to give other contributing employers assurance that the levy is being used to deliver high quality legitimate apprenticeship training? All provision should be subject to the quality requirements set out in the response to question Should training providers that can receive levy funding have to be registered and/or be subject to some form of approval or inspection? Yes No The SFA provider register should be used and developed to ensure that only high quality providers can be involved in the delivery of apprenticeships to the standards described above. We are concerned that trailblazer apprenticeship standards do not require qualifications, although some employer groups have decided that one or more qualification should be included. We believe therefore that to ensure quality, all apprenticeships should be submitted to Ofqual for accreditation. Only these apprenticeships should be funded via the levy. An inspection system should be established, although we do not believe that Ofsted is appropriately structured and resourced to take responsibility for this. An alternative could be that the sector boards (described above) carry out inspection. 18. If providers aren t subject to approval and inspection, what checks should we build in to the system to give contributing employers assurance that the levy is being used to deliver high quality legitimate apprenticeship training?

13 All of those determinants of quality described in Q11 above and the accreditation of apprenticeship programmes by Ofqual. 19. What other factors should we take into account in order to maximise value for money and prevent abuse? No comment.

14 The levy is simple 20. How should the new system best support the interests of year olds and their employers? Higher cost ceilings should be provided for employers taking on apprenticeships aged years. This will allow for additional support, through for example, mentoring. This additional support for younger apprentices should be included in apprenticeship frameworks and the signed training plans, which should be co-signed by parents/guardians. Unions should be involved as they are well-placed and equipped to play an important role in supporting employers and young apprentices. We are concerned that apprenticeships will be the only alternative for the many year olds who are unable to access other vocational education opportunities as a result of the significant cuts to further education funding over the past five years. However, an apprenticeship should only be offered to a young person if it is appropriate to the needs and ambitions of the individual learner. Systems need to be in place to ensure that year olds are not persuaded to start programmes to enable employers to achieve apprenticeship targets and therefore benefit from levy funding. This is best carried out though well-funded and coordinated careers education, information and guidance in schools, which should include specialist careers advisors who can support young people to identify good quality apprenticeships, if that is the appropriate route for them. 21. Do you agree that apprenticeship levy funding should only be used to pay for the direct costs of apprenticeship training and assessment? Yes No The direct costs for which employers can claim the apprenticeship levy funding must be carefully stipulated to prevent misuse of funds. These costs may vary by sector, and the sector boards must determine these. Any surplus in the overall levy pot should be used to develop and market apprenticeships. The use of this funding should be determined by the National Levy Board in consultation with the sector boards. 22. If not, what else would you want vouchers to be able to be used for and how would spending be controlled or audited to ensure the overall system remains fair?

15 N/a 23. Are there any other issues we should consider for the design and implementation of the levy that haven t been covered by the consultation questions we have asked you? Yes No The employer liable for the levy needs to be defined by government as this will determine whether school budgets will be impacted by the need to pay the levy. It will need to decided, for example, whether academy chains are the employer (as many of these may be determined as large ). Similarly, will local authorities be defined as the employer of teachers in maintained schools? If so, will this levy be passed down to the schools budgets, and is this a good use of public funds which would otherwise be spent on educating children and young people? Do you have any other comments that might aid the consultation process as a whole? Please use this space for any general comments that you may have, comments on the layout of this consultation would also be welcomed. Thank you for taking the time to let us have your views. We do not intend to acknowledge receipt of individual responses unless you tick the box below. Please acknowledge this reply

16 At BIS we carry out our research on many different topics and consultations. As your views are valuable to us, would it be okay if we were to contact you again from time to time either for research or to send through consultation documents? Yes No