LIVERPOOL CITY REGION EMPLOYMENT AND SKILLS BOARD RESPONSE TO PUBLIC SECTOR APPRENTICESHIP TARGET CONSULTATION

Transcription

1 LIVERPOOL CITY REGION EMPLOYMENT AND SKILLS BOARD To: Department for Business, Innovation and Skills Date: March 2016 RESPONSE TO PUBLIC SECTOR APPRENTICESHIP TARGET CONSULTATION 1. Liverpool City Region Employment and Skills Board 1.1 The Employment and Skills Board is the Liverpool City Region s lead strategic voice for improving the employment, skills and productivity of the City Region s residents and workforce. It reports directly into the Combined Authority fulfilling a representative role and also one of challenge. 1.2 The Board continues to bring together a number of private and public sector stakeholders to oversee a range of employment and skills-focused activity, including the co-ordination of the Apprenticeship Hub and the ongoing Skills for Growth work. 2. Response to consultation 2.1 Do you agree that the organisations listed and public corporations (at least with headcount of 250 or more in England) should be in scope for the Apprenticeship Target? The Liverpool City Region welcomes Government s ambition to increase high quality Apprenticeships amongst employers of all sizes, in all sectors. The Liverpool City Region s Employment and Skills Board continues to bring together a number of private and public sector stakeholders to oversee a range of activity, including the co-ordination of the Apprenticeship Hub and the ongoing Skills for Growth work. Through this activity, the Employment and Skills Board has a comprehensive understanding of the benefits that Apprenticeship provision brings to the City Region s employers, residents and wider economy. 2.2 In its response to Government s initial Apprenticeship Levy consultation, the Liverpool City Region stated that any funds raised from the introduction of a Levy should be in addition to current Apprenticeship funding allocations received by training providers, as opposed to a replacement. Page 1 of 5

2 2.3 The Liverpool City Region recognises Government s intention to increase Apprenticeship take up in the public sector through the proposed introduction of an Apprenticeship target for the organisations listed at Annex 2. However, it is disappointing that this proposal appears to only recognise public sector organisations role as employers: rather than as commissioners, procurers and wider influencers within local areas. In order to truly understand the positive impact that public sector organisations have on Apprenticeship take up, Government should consider these wider roles played by organisations across recognised partnerships, such as Combined Authorities. 2.4 In addition to this, the Liverpool City Region does not recognise the headcount of a number of local organisations listed in Annex 2 and is concerned that these headcounts provide an inaccurate sense of scale which could potentially impact both an organisation s Levy payment and Apprenticeship target. The Liverpool City Region would hope that an organisation s Apprenticeship Levy payment and Apprenticeship employment target would be based on the number of FTE posts and agreed in consultation with the payroll and HR functions of the respective organisation before the Levy was implemented, in order to ensure accuracy. 2.5 Furthermore, the proposed Apprenticeship employment target of 2.3% on individual organisations is likely to impose significant cost on public sector organisations and disrupt sustainable workforce planning at a time of ongoing financial constraint. The Liverpool City Region believes that any monitoring of public sector Apprenticeship take up should be considered against a locally-defined measure which is: Reflective of public sector organisations role as employers, commissioners, and procurers; Measured across a locally-defined place based group of partnership organisations; Monitored across a time period that encourages sustainable workforce planning; and Reported locally and not subject to any Government compliance action. 2.7 In order to ensure high quality Apprenticeship take up across the whole public sector, Government should extend the support of account managers from the National Apprenticeship Service to all public sector organisations, including local government bodies. 2.8 In developing further incentives to increase Apprenticeship take up in the public sector; Government should consider abolishing employer NI contributions for Apprenticeships within public sector organisations, not just for those aged below 25 years old. In order to discourage any potential misuse of this policy (i.e. gaming), this could be further developed to ensure that the NI abolition was valid only for a set of locally-agreed, relevant Apprenticeship standards (i.e. type and level): perhaps linked to innovation in public sector Apprenticeship standard development or wider public service reform. Page 2 of 5

3 2.9 Should certain bodies be grouped together for the purposes of the target? Yes, In order to truly understand the impact that public sector organisations have on Apprenticeship take up, Government should consider the wider role of organisations across locally-defined partnerships, such as Combined Authorities. As highlighted earlier, any monitoring of Apprenticeship take up should be considered against a locally-defined measure which takes into account a local partnership s role as an employer, commissioner and place shaper The Liverpool City Region s geography reflects a functional economic market area, with a majority of residents living and working within the area. The geography is unique across the country in that it is coterminous with the administrative boundaries of the Combined Authority, Local Enterprise Partnership area and Job Centre Plus. Both locally and nationally, the Liverpool City Region is recognised as the definitive local geography for public sector partnership working in relation to skills policy development. Most recently, this was demonstrated by the agreement and ongoing implementation of the City Region s Devolution Deal with Government The Liverpool City Region Combined Authority is focused entirely on strategic governance to facilitate economic growth across the City Region: this includes employment and skills functions fulfilled by the Employment and Skills Board and the co-ordination of the local Apprenticeship Hub. The Combined Authority and its constituent members have a well-established history of working together to ensure that they and wider public sector stakeholders remain focused on ensuring residents and businesses can realise their economic potential. This includes extensive promotion of the benefits of high quality Apprenticeship provision that responds to the needs of the local economy As previously noted, the Liverpool City Region s recent Devolution Deal with Government further underlines the importance of the Combined Authority s role and partnership working across the public sector locally. Consequently, the Liverpool City Region is clear that any measurement of Apprenticeship take up should reflect the collective impact of public sector organisations across locally-defined place based partnerships (i.e. the City Region as a whole) The collective perspective offered would also provide the basis for different models of delivery such as an Apprentice Training Agency or a Group Training Association. This could offer apprentices different training in roles in different organisations that would benefit them and the organisations over the longer term Do you agree that headcount is the correct basis for the target? No, Full Time Equivalent figures should be the basis for any target. Public sector organisations across the Liverpool City Region continue to uphold a long-standing commitment to promote a flexible working culture for employees. The updated definition of an Apprenticeship, set out in Government s Enterprise Bill, states that an Apprentice must be employed on a contract of at least 30 hours per week. This definition removes the opportunity for current and potential employees working under 30 hours per week to undertake an Apprenticeship: making the proposed use of employee headcount an irrelevant and incomparable metric for measuring Apprenticeship take up. Page 3 of 5

4 2.15 The Liverpool City Region welcomes Government s acknowledgement that Full Time Equivalent employee numbers could be a more useful measure and is clear in its view that any monitoring of Apprenticeship take up should be done so in this context Do you think there is any further information that should be provided? Yes. The Liverpool City Region recognises Government s intention to increase Apprenticeship take up in the public sector through the proposed introduction of an Apprenticeship target for the organisations listed at Annex 2. However, it is disappointing that this proposal appears to only recognise public sector organisations role as employers; rather than in their broader role as influencers and purchasers with strong links to the local economy In order to truly understand impact of public sector organisations contribution to increased take up of high quality Apprenticeships, the Liverpool City Region is clear that Government should consider the significant influence that public sector organisations have as commissioners and procurers within local areas. Practically, this would mean that any Apprenticeship opportunities created through commissioned, contracted or shared services would be counted, as part of the relevant public sector partnerships measure of Apprenticeship take up Despite the additional detail published in the consultation document and Government s Enterprise Bill, it remains unclear as to the proposed implications for public sector organisations that did not meet or achieve an Apprenticeship target or measurement. The Liverpool City Region is clear in its view that any monitoring relating to public sector Apprenticeship take up should be defined and reported locally and that the measure would not trigger any compliance action from Government Government does state that it anticipates a limited number of enforcement actions in relation to Apprenticeship take up within the private sector as it assumes most employers will spend their Levy allocation. Following the recent agreement and ongoing implementation of the City Region s Devolution Deal with Government, the Liverpool City Region Combined Authority continues to be recognised as the definitive local body for skills policy development. In keeping with this, the Liverpool City Region is clear that any unspent Apprenticeship Levy allocation from private sector businesses within the City Region should be redistributed to the Combined Authority to help continue its work in encouraging the take up of high quality Apprenticeships Do you agree that the target periods set out are correct? No. The proposed introduction of any Apprenticeship employment target is likely to impose significant cost on public sector organisations and disrupt sustainable workforce planning at a time of unprecedented and ongoing financial constraint. The Liverpool City Region recognises that any local monitoring of Apprenticeship take up should be aligned to the financial year, in order to minimise any further impact on public sector resource The City Region would also welcome a staged approach to the target, if it is to be imposed, recognising that workforce plans of organisations can take time to implement. The Liverpool City Region is clear in its view that any monitoring Page 4 of 5

5 relating to public sector Apprenticeship take up should be defined and reported locally. However, it recognises Government s own target of increasing Apprenticeship take up by 2020 and is clear that any national reporting of Apprenticeship take up in the public sector would be aligned to this timescale Do you have any other comments about the contents of this consultation document? With continuing downward pressure on public sector budgets, the Liverpool City Region finds it disappointing that Government s proposal appears to only recognise public sector organisations role as employers: rather than as commissioners, procurers and wider influencers within local areas. This recognition would allow organisations locally to collaborate fully to take full account of the Apprenticeship Reforms being proposed and implemented by Government. This would in support of wider public service reform in the City Region and the provision of clear progression pathways for individuals The Liverpool City Region does not recognise the headcount of a number of local organisations listed in Annex 2 and is concerned that these headcounts provide an inaccurate sense of scale which could potentially impact both an organisation s Levy payment and Apprenticeship target. The Liverpool City Region would hope that an organisation s Apprenticeship Levy payment and Apprenticeship employment target would be based on the number of FTE posts and agreed in consultation with the payroll and HR functions of the respective organisation before the Levy was implemented, in order to ensure accuracy The Liverpool City Region believes that any monitoring of public sector Apprenticeship take up should be considered against a locally-defined measure which is: Reflective of public sector organisations role as employers, commissioners, and procurers; Measured across a locally-defined group of partnership organisations; Monitored across a time period that encourages sustainable workforce planning; and Reported locally and not subject to any Government compliance action. Page 5 of 5