22 May BIS/DfE Joint Apprenticeships Unit Department for Business Innovation & Skills Orchard 1 1 Victoria Street London SW1H 0ET

Transcription

1 22 May 2013 BIS/DfE Joint Apprenticeships Unit Department for Business Innovation & Skills Orchard 1 1 Victoria Street London SW1H 0ET Response made via online survey. Dear Joint Apprenticeship Unit ICAEW submission to the Future of Apprenticeships in England: Next Steps from the Richard Review The Institute of Chartered Accountants in England and Wales (ICAEW) welcomes the opportunity to provide written evidence to Future of Apprenticeships in England. Our written submission covers: Key messages and recommendations; Our response to core questions. We would be happy to provide oral evidence to BIS. Please contact me on the details provided in my signature if you would like to discuss our submission further. Yours faithfully Jonathan Gorvin Policy & Regulation Manager D T +44 (0) M +44 (0) E: jonathan.gorvin@icaew.com - The Institute of Chartered Accountants in England and Wales T +44 (0) Chartered Accountants Hall F +44 (0) Moorgate Place London EC2R 6EA UK DX 877 London/City - icaew.com 1

2 WHO WE ARE 1. ICAEW is a world-leading professional accountancy body. We operate under a Royal Charter, working in the public interest. ICAEW s regulation of its members, in particular its responsibilities in respect of auditors, is overseen by the UK Financial Reporting Council. We provide leadership and practical support to over 140,000 member chartered accountants in more than 160 countries, working with governments, regulators and industry in order to ensure that the highest standards are maintained. 2. ICAEW Chartered Accountants provide financial knowledge and guidance based on the highest technical and ethical standards. They are trained to challenge people and organisations to think and act differently, to provide clarity and rigour, and so help create and sustain prosperity. We ensure these skills are constantly developed, recognised and valued. 3. ICAEW Chartered Accountants advise 1.5m UK businesses and are the largest source of business advice in our country. 4. ICAEW, PwC and other partners, have led the development of a new Higher Apprenticeship Programme for professional services, focusing on tax, audit and management consultancy. This programme, in collaboration with the Association of Taxation Technicians (ATT) and the Management Consultancies Association (MCA), aims to deliver 1,500 Higher Apprenticeships over the period to March KEY MESSAGES AND RECOMMENDATIONS 5. Apprenticeships should aim to deliver skills training which are of benefit to the economy and to social mobility. The accountancy profession contributes to 14.4bn to Gross Value Added 1 to the UK economy and our Higher Apprenticeship Programme enables employers to access otherwise untapped, under-represented talent. 6. Employers should decide on the best approach for Apprenticeships within their sector. We recommend that employers should be at the heart of standards and that it is for them to decide on whether one standard or qualification is appropriate for that particular occupation or job role. 7. Apprenticeships should align with the requirements of professional registration. This will give Apprentices a sustainable future within their chosen profession and allow flexibility across different employers and sectors. It also ensures that they meet any statutory requirements for that profession. 1 UK Employer Skills Survey 2011 (UK Commission for Employment and Skills) 2

3 8. When developing the proposed new standards existing best practice should be conserved. We believe it is important to ensure that existing frameworks which are considered successful, particularly those that have been publicly funded, are retained. There is a real risk that frameworks which are valued by employers, Apprentices and government, could be lost in the change to standards. QUESTIONS Question 1: How can we ensure that every Apprenticeship delivers substantial new skills? We agree that Apprenticeships should deliver substantial knowledge and skills which in turn are of benefit to the economy and social mobility. This could be for existing employees moving to higher skilled roles, or for new employees. It is important that Apprenticeships give opportunities for individuals to progress to the top of their profession and therefore, where possible, standards should align to the requirements of professional registration. Question 2: How should we invite and enable employers to come together to design new standards for Apprenticeships? We believe that frameworks or standards need to be developed collaboratively between employers and other stakeholders. Frameworks developed to meet the requirements of the Higher Apprenticeship Fund required strong industry partnerships to meet employer needs, and we would suggest that future standards be developed on a similar basis. For example, the professional services Higher Apprenticeship Programme, for which ICAEW is a partner, was designed by employers to meet their needs in a changing labour market. It includes a blend of professional qualifications and business skills that professional services employers consistently say they need. In addition, by providing a recognised alternative route into the sector, the professional services Higher Apprenticeship Programme has enabled employers to access otherwise untapped, under-represented pools of talented individuals. Question 3: What are your views on the proposed criteria for Apprenticeship standards as set out in section 2 of the document? We support the criteria set out in section 2, but would note that Apprenticeship standards should, where possible, be aligned to the requirements of professional registration bodies and ultimately allow Apprentices to gain Chartered status. This will ensure Apprentices achieve the highest professional recognition and, in most cases, also begin a cycle of continual professional development after completing the training, ensuring a commitment to lifelong learning. Professional ethics is also important and a key component of many professional qualifications. We would recommend embedding professional ethics within 3

4 Apprentice standards, particularly at higher levels, to give public and employer confidence. We would also suggest that standards need to be sustainable, commercially viable and kept relevant through periodic review. Question 4: Should there be only one standard per Apprentice occupation/job role? Yes No Don t know Please explain your response: One standard per occupation may simplify the scheme, but we believe there is a risk that it could create Apprenticeships that are potentially too broad to meet employer demands. We would highlight that many occupations, such as accountancy or engineering, are multi-disciplinary in nature and it is important that separate routes be created where required. This could be done by creating separate standards, or by creating streams within existing standards, as can be found in the professional services Higher Apprenticeship framework. Ultimately, we believe that industry should decide on how many standards or qualifications are required for that sector. It is also important that any classification of occupation/job role is led by employers, professional bodies and other stakeholders, who are in the best position to identify these. Question 5: Should there be only one qualification per standard? Yes No Don t know Please explain your response: As above, we believe that this should be sector led, as there is a risk that qualifications currently valued by employers could be lost, which may affect an employer s decision to train Apprentices. For example, the UK accountancy profession has several professional bodies that regulate and offer qualifications across a number of areas. The proposal currently put forward may not work in practice, as it means employers are not able to choose the most appropriate accountancy qualification for their Apprentice. Question 6: How should we manage the transition from the current system of Apprenticeship frameworks to a new system of employer-designed Apprenticeship standards and qualifications? We believe it is important to ensure that existing frameworks which are considered successful, particularly those that have been publicly funded, are retained. There is a 4

5 real risk that frameworks which are valued by employers, Apprentices and government, could be lost in the change to standards. When transitioning to the new standards, we recommend reviewing frameworks that already broadly meet the suggested criteria, before moving to those that are furthest away from the new expectations. This will give those frameworks that are furthest away the opportunity to benchmark against those closest to the standard. Question 7: How can we make sure that the new standards stay relevant to employers, and are not compromised over time? We suggest that standards should be periodically reviewed through open consultation within the sector to help ensure they stay relevant. This could be done through sector skills councils or through other industry partnerships. Maintaining different qualifications within standards would also help ensure that they remain relevant to employers over time through competition and innovation. As too would aligning standards to well respected professional qualifications. For example, every year we update the ACA syllabus and look for areas where the content needs to evolve to keep pace with regulatory and statutory changes. Then every five to six years we do a full review which includes extensive consultation with stakeholders from around the world to ensure it remains flexible, current, relevant and meets the needs of the market - now and in the future. Question 8: How can we ensure that employers are better engaged with the development and oversight of the assessment in Apprenticeships? Answered as part of question 9. Question 9: How could employers best be involved in the practical delivery of assessment? As part of its principal qualification, the ACA, ICAEW accredits employers to be Authorised Training Employers. Training employers are integral to signing off that the required work experience has been undertaken, planning and implementing training programmes, ensuring students are adequately supervised, and that experience and exam progress is reviewed six monthly. Final sign off by the employer is also required to ensure that the candidate is fit and proper. This puts employers at the heart of the qualification, but equally ensures that they are not overburdened. Question 10: How can the independence and consistency of assessment in Apprenticeships be further improved? We believe that independence is important for assessment, either though through external assessment or by third party monitoring. 5

6 There may be some situations where an organisation is both trainer and assessor. In such cases the awarding body should ensure that the appropriate control measures are in place in order to safeguard independence. Question 11: How should we implement end point assessment for Apprenticeships? We believe different sectors will have different requirements in regards to assessment and that it should be for employers and other stakeholders to work out how best to implement end point assessments within their standards. Question 12: How should we implement grading for Apprenticeship qualifications? This question suggests that grading for Apprenticeships has already been agreed and that it is now being asked to comment on how to implement such grading. We would highlight that grading may not be appropriate for professional qualifications. We believe that Apprentices should either pass or fail. This is consistent with a number of professional qualifications, where grades are not awarded. For example, many professional qualifications leading to Chartered status, including the ACA, are awarded on a pass or fail basis. Question 13: What are the specific obstacles to all Apprentices achieving level 2 English and maths as part of their Apprenticeship, and how could these be overcome? A major policy challenge is the level of maths and English attainment young people have achieved once leaving school. Our research with Centre for Cities suggests that weaker city economies lack the local skills base in maths and English to grow. This becomes problematic when looking to enrol students from outside of major cities or disadvantaged backgrounds. One way that this could be mitigated in future, is for the national curriculum and schools to strengthen their focus on maths and English. That way, before a student takes on their apprenticeship, they are more prepared and skilled to overcome the level 2 requirements. Students need to be given the tools to better prepare themselves when they are in the education system. That is why we are supporting the Personal Finance Education Group (PFEG) campaign to include financial education in national curriculum; it is an innovative way to teach maths within a personal and professional development context. Question 14: How would a requirement to have all Apprentices achieve level 2 in English and maths impact on employers, providers and potential learners? What are the risks and potential solutions? Answered as part of question 13. 6

7 Question 15: What further steps, by government or others, could encourage greater diversity and innovation in training delivery to help Apprentices reach the standards that employers have set? No response. Question 16: What approach would work best to ensure Apprentices benefit from time to train and reflect away from their day to day workplace? No response. Question 17: Should off-site learning be made mandatory? Yes No Don t know Please explain your response: While strictly off-site learning may not be necessary in all circumstances, we believe that Apprentices should be given an appropriate amount of time to pursue the necessary learning, outside of the normal working environment. Question 18: How can the process for approving training providers be improved, to help employers find high quality, relevant training? Many professional bodies already accredit learning providers, certifying that they meet the high quality required by the body. For example ICAEW has over 100 Partners in Learning in the UK, which are featured on our website and are easy for employers to find: Question 19: Do you believe that a kitemarking scheme for your sector or profession would add value and be supported? Yes No Don t know Please explain your response: As a Chartered professional body, we believe in acting responsibly, in the best interests of our members and the general public. We act with integrity, creating effective partnerships with organisations and communities worldwide to ensure the highest technical, professional and ethical standards. As such, we believe that professional bodies already allow for a form of kite marking; with logos which are instantly recognisable within their sectors and provide the necessary assurances to employers. 7

8 Question 20: What more can government do to facilitate effective third party/external use of its data to better inform individuals and employers about Apprenticeships? No response. Question 21: What approaches are effective to inform young people and their parents about the opportunities provided by an Apprenticeship? Answered as part of question 22. Question 22: How can we support employers to engage with learners of all ages to provide information about Apprenticeship opportunities? ICAEW runs a successful Careers Adviser Network (ICAN). ICAN encourages trainee and qualified ICAEW Chartered Accountants to volunteer in their local schools, colleges and universities to help provide careers guidance. We believe this scheme could be replicated within other professions, to raise awareness of apprenticeships and other routes to qualification. ICAEW also hold a National Schools Competition in partnership with industry. ICAEW s Business, Accounting and Skills Education (BASE) games are a series of fun, educational business games for 16 to 19-year-old students. Last year, 1,500 students took part in regional heats representing over 200 schools across the UK. BASE challenges students to work in teams to tackle a business scenario. With the help of a professional mentor, they take the role of ICAEW Chartered Accountants to analyse, debate, and then present their recommendations to a panel of experts. It provides students with an opportunity to develop transferable employability skills, broaden their knowledge of business, and showcase their talents to employers with 10 national, and a number of local employers, sponsoring our heats and national final last year. In 2013, we will be running the Apprentice Business Challenge, a new national competition for Apprentices on the Accountancy, Project Management or Professional Services Higher Apprenticeship programmes. This national competition is based around an interactive business game designed to test the knowledge, skills and creativity of Apprentices, and their approach to working as part of a team on a real business issue. It helps Apprentices to practice and develop the skills and commercial awareness that are required to be successful in the workplace. Question 23: Do you consider that the proposals set out in this document would have a positive or negative impact on any group, including those with protected characteristics? Please provide any comments or evidence you have for your answer and set out which aspects of the reforms will impact and how these impacts might be managed. No response. 8

9 Question 24: Do you have any further comments on the issues in this consultation? Section 6: Giving employers the purchasing power and incentives to drive quality and value This area is not covered in the consultation questions, but we support the principle put forward in the review that the funding system should be simple and accessible, thereby helping to expand high quality Apprenticeships by encouraging employers and individuals to participate. We do not agree with the proposal that Apprenticeships should be funded through the tax system because this is likely to introduce complexities that deter businesses from taking on Apprentices. R&D tax credits have proved a useful incentive after a shaky start but are being made more complicated this year, and tinkering with other aspects of tax and NIC would create additional burdens and costs for employers who are having to cope with PAYE in real time and auto-enrolment. We recommend that, in the interests of simplicity and accessibility, businesses be paid grants to incentivise them to take on Apprentices, and that they apply for such grants direct to the Department responsible for Apprentices, ie BIS or DfE. 9