Response to Consultation on Review of Apprenticeship Training in Ireland

Response to Consultation on Review of Apprenticeship Training in Ireland Name of Organisation: Association of Chartered Certified Accountants, Ireland Address: 9 Leeson Park, Dublin 6 Occupational sectors which are covered in the submission: Accounting and Finance Date of submission: 28/8/13 The submission should be made by e mail to Apprenticeshipreview@education.gov.ie by close of business on Friday 30 August 2013. Please note that all submissions will be published on the website of the Department of Education and Skills. 1

Consultation on Review of Apprenticeship in Ireland. Suggested issues for submissions. Area 1 Overview 1 Having regard to the issues outlined in the Press Release and Discussion Paper, please set out your views of the effectiveness of the current apprenticeship programme, highlighting the issues you consider should be addressed to ensure a skilled workforce to meet Ireland's current and future needs. According to the Department of Education and Skills, the apprenticeship scheme was last reviewed in 1986. At that stage the focus of the apprenticeship scheme was to up skill individuals in various trades. This responded to economic needs at that time. In the intervening years the economy has changed dramatically. As Ireland is evolving to be more of a knowledge-based economy, ACCA believes that the scope of the apprenticeship should be expanded to include these knowledge-based skills. Accountancy skills would be a key component of this. 2 Please set out an overview of your ideal model for apprenticeship in the future, indicating whether the programme should be extended to cover new occupations, and whether there should be various sub models for different fields of activity. ACCA is the global body for professional accountants. To enable employers to train school leavers or entry level employees, a structured career path with clear certification for learning outcomes and benchmarked work experience ensures a consistent standard across the different specialisms within accountancy. ACCA would recommend extending the apprenticeship model to cover the accountancy sector as the accountancy profession, and its associated training, is built around a model of technical training and professional experience which mirrors the ethos of apprenticeships. The apprenticeship model is ideal for entry level and school leaver training in accounting and within the profession this level of competency is referred to as Certified Accounting Technician (CAT). This differentiates the technician level from the professional accountant who undergoes a further period of training including three years of work experience, exams at undergraduate and Masters level as well as further ethical training. In addition, there are a number of different specialisms within accounting including (but not exhaustive) audit, tax, professional services/advice and financial management. 2

3 How should the Irish apprenticeship system fit into the EU and international structures? The current Irish apprenticeship system could be modified to fit more neatly with the International Federation of Accounting Committee s (IFAC) recommendations on initial training. The educational standards are set by the International Accounting Education Standards Board (IAESB) and entry into the profession is published at: www.ifac.org/publications-resources/international-education-standard-ies-1-entryrequirements-professional-accoun An apprenticeship in accounting could be designed to merge with the entry route into the profession to enable progression for those successful at the technician / apprenticeship level. As a global professional accountancy body, ACCA is a member body of IFAC and adheres to the standards set by the IAESB for all training and qualification requirements. 3

Area 2. Looking forward, what changes would you recommend in a restructured or fundamentally reformed apprenticeship system in regard to any or all of the issues below. Please feel free to consider a significantly broader approach which embraces a wide range of occupations, and provides for different modes of funding and delivery. 1. Governance 1a Should future apprenticeships have a statutory underpinning? What aspects, if any, should be statute regulated, and what aspects should be market or stakeholder controlled? ACCA believes that any future apprenticeships schemes should have a statutory unpinning from an educational perspective. All professions need to be formally regulated to ensure that participants receive comprehensive skills training while adding value to the employer s business. A statutory framework would be helpful as standards can be agreed and applied consistently to ensure employees in different functions attain the same standard. However professional oversight does not exclude participating professions being able to demonstrate self-regulation. The statutory body would be responsible for, and consult with trades and occupations when, defining the curriculum and recognition of level of award / learning outcomes whilst the employer would be responsible for the salary of the apprentice. Recruitment would be shared between the statutory body and employer. 1b How and who should be involved in planning, curriculum development, support, regulation and monitoring of apprenticeships to ensure compliance with national objectives? (Quality assurance to be through Quality and Qualifications Ireland (QQI)) Key stakeholders for the above should include: Employers Tuition providers Regulators State agencies such as IBEC, IDA, Enterprise Ireland Government departments including the Department of Jobs, Enterprise and Innovation and the Department of Education and Skills In the accounting profession, global standards are set by IFAC through the IAESB. To ensure consistency between global and Irish standards, ACCA would want to work with key stakeholders listed above and other appropriate Irish regulators. 4

1c What would be the most effective system of governance to combine long term system and brand stability with an agile response to national needs. How can governance arrangements be simplified streamlined? As there are no current apprenticeships in accounting, ACCA would like to suggest a new implementation processes. ACCA have experience of initial educational and vocational schemes across a number of countries, some of which would be suitable for the Irish market. England www.gov.uk/government/publications/specification-of-apprenticeship-standardsfor-england http://www.apprenticeships.org.uk/partners/sase.aspx Scotland www.skillsdevelopmentscotland.co.uk/our-services/modernapprenticeships/modern-apprenticeship-group/modern-apprenticeshipframeworks/accounting/ Wales http://wales.gov.uk/topics/educationandskills/skillsandtraining/apprenticeships/pro viders/sasw/?lang=en 2. Equity 2a How can a better gender balance be achieved in apprenticeships? ACCA believes that Professions which are more accessible to both genders should be encouraged. The professions which have been associated with the apprenticeship scheme in Ireland have been traditionally trade and craft oriented professions which tend to attract more male applicants. Also professions as such as construction and electronics do not encourage flexible working arrangements and this can be a barrier for women hoping to re-enter the work force. ACCA prides itself on gender diversity. Over 50% of ACCA students globally studying the qualification are female. Accountancy is generally seen as an occupation where work life balance is more achievable, job sharing, part time work and project work are common practice within the industry. 2b How can education and training and labour market entry routes for early school leavers, and those ill equipped for direct entry to more academically oriented FE and HE programmes, be best protected and expanded? The apprenticeship scheme should be expanded to include sectors which are experiencing expertise shortages, such as the IT and Financial Services sectors. Individuals opting for the direct entry route (with no prior education achievements) 5

into any apprenticeship schemes should be enrolled in a general induction programme to equip them with standard business skills including literacy, IT and finance skills. From there students can then expand their training into their chosen profession. ACCA would welcome an agreed minimum level of competency in numeracy and IT skills when a trainee completes their apprenticeship. 2c How can the interests of persons with disabilities be advanced within future apprenticeships? Students with physical disabilities may struggle to secure placement on the existing scheme as the professions in the current programme are physical in nature. The scheme should be extended to include more office-based occupations such as accountancy, IT programming and office administration. It is also important that training should be flexible and accessible to ensure greater participation of individuals with disability. Online learning and computer-based exams should be available in any new programmes. 3. Range of Occupations 3a Should the range of occupations covered by the apprenticeship/traineeship be broadened outside the traditional craft industries? If so what occupations/programmes should be covered and how would this be achieved? Please state why you consider these occupations suitable for apprenticeship. Yes, ACCA believes that the range of occupations should be expanded. The opportunities in traditional craft industries are declining whereas industries such as science, IT and finance are growing. Also the existing scheme, by its very nature, is not as inclusive as it could and should be. By expanding the range of occupations covered in the scheme, greater participation among women and people with disabilities would increase, thereby helping to meet the needs of successful organisations. Finance, accounting and business are obvious areas for expansion under an apprenticeship scheme as these create pathways and opportunities for trainees to continue their professional training post-apprenticeship. ACCA would be able to offer a pathway to full membership for those starting on an apprenticeship in accounting. 4. Funding 4a How can the cost of apprenticeship be shared between apprentices, employers and the State? 6

ACCA suggests that both the employer and the state benefit from the skills improvement enjoyed by the apprentice. It is therefore reasonable to propose that the costs of employment and training are shared between the employer and the state. The employer should supplement the apprentice s salary, similar to the JobBridge. The amount of this supplement would depend on the sector but between 100-150 euro a week would be reasonable. Training and development costs would be assumed by the State. It is unrealistic to assume financial cost can or should be absorbed by the apprentice. 4b How can the cost of expansion into new disciplines be best supported given economic constraints. The current structure of the apprenticeship programme is between three and four years, a significant amount of this programme is conducted in training as opposed to experience in a practical environment. ACCA would suggest a model whereby an apprentice is contracted to work for the employer for a minimum of 80% of the working week and the remainder would be devoted to completion of the course curriculum in the most appropriate teaching and learning environment. This could be delivered through face to face classroom learning or online study. The structure that ACCA proposes will enable the apprentice to make an immediate contribution to the economy. 4c Who should pay the learner (a) on the job (b) off the job? In ACCA s model the apprentice works full time in an accounting support role for a year, while studying the course part-time. Therefore it would be a combination of the State paying for the training component of the apprenticeship and the employer paying the apprentice. 4d Should pay or allowances vary by discipline? Yes. ACCA believes that skills and industry remuneration should dictate pay and allowances. 4e What supports, if any, should be available for leaners availing of off the job training away from home? E learning should be provided where possible to ensure that learners can avail of tuition and training while they are away from home. As ACCA would require formal assessment of the learning outcomes for an apprentice, it is likely that each individual will require some tuition and revision support. Although the assessment can only happen within an invigilated environment, the teaching can be delivered in a number of different ways. This 7

includes traditional face to face teaching as well as blended and digital learning solutions. A range of tuition support solutions provide the best choice for the employer and apprentice. 4f Describe how the changes you propose will decrease or increase the cost of apprenticeship and how should this be done? Tuition and exam fees will be an additional cost to the State; however the provision of e-learning should reduce the cost of delivering tuition to new learners. The model that ACCA proposes is significantly shorter (one to two years) than the existing model and therefore it will incur fewer overall costs for the State and employer. Providing a salary to apprentices will be an additional cost to employers but depending on the sector this will be limited to 100-150 euro per week. Proposing a different model which enables flexibility over the length of the apprenticeship decreases cost as only the able and well-motivated will make progress through the different levels. 5 Recruitment 5a Who should control recruitment to apprenticeships and how should this be done? Recruitment will be driven by industry demand however it should be overseen by the governing body with final apprenticeship selection determined by the employer. 5b Given that an agile response to labour market needs inevitably gives rise to peaks and valleys in demand, how can the impact of this on planning, infrastructural investment, and employment of trainers, be best catered for? Initiating a modular approach to the apprenticeship would enable flexibility, for example a school leaver with basic skills may be given the opportunity to start a two year apprenticeship but if the apprentice does not make sufficient progress within any given year, the apprenticeship will cease. Since tuition for ACCA s qualification is available online, investment in infrastructure and employment of trainers will not be an issue. As previously outlined, ACCA is proposing a one or two year apprenticeship programme therefore the timeframe between training and completion is shorter and as a result is responding quicker to the labour market needs. 8

5c Should State provision of training be decoupled from employer recruitment? No, in the case of entry level accountants the provision of training and the practical application of this training through full time employment go hand in hand. Indeed it is crucial that the application of newly acquired knowledge is practised within the professional environment. 5d How can the supply and demand for the different disciplines be most effectively planned? Demand and future economic requirements can be assessed through existing market analysis such as the Forfas employment survey. Additional indicators can be assessed through the Departments of Jobs, Enterprise and Innovation and Social Protection. Within finance and business there are a number of specialisms including audit, tax, financial management, and professional services. These specialist functions share the same core skills and knowledge and therefore, should there be a sharp increase in the demand for one function, it would be relatively simple to redistribute apprentices across these sectors. 5f What should be the minimum entry requirements? Should these vary for individual occupations? ACCA does not have a minimum requirement for entry to its programme. However, for the purpose of an apprenticeship we would be recommend that individuals should have either to show ability through their school examination record or pass basic skills modules in linguistic, finance and IT skills before completing the apprenticeship. Should there be a probationary period? ACCA would recommend a two month probation period. 9

6. Curriculum 6a What is the appropriate balance of (a) technical and occupational skills and (b) transversal skills, and what subjects should be added or strengthened in the programme? (e.g Transversal skills could include mathematical skills, ICT, communications, literacy, teamwork, planning, research and evaluation skills)? The ACCA programme is designed around the Complete Finance Professional. ACCA research reveals that the vast majority of CFOs looking to appoint new staff for their businesses believe it important for each potential employee to have both a breadth and depth of finance expertise and capabilities. With this in mind, the ACCA Qualification has been uniquely created to develop the full range of competencies finance professionals need in the corporate sector today. The ACCA Qualification covers everything that a professional accountant needs to know. It is a complete syllabus and no important areas of knowledge or skill are left out. Particularly important is that, as well as covering vital areas of strategic management, risk and planning, it also covers the other key areas where finance professionals need a firm grounding including financial reporting, tax and audit. This gives the correct balance between full time employment, where employees will benefit from additional transversal skills such as communication skills, teamwork and planning, in addition to the academic side of the qualification. All learners should also be provided with the appropriate induction programme to ensure they have a basic understanding of business and IT skills. ACCA s apprenticeship programme is designed to be delivered in a professional environment such as within a finance team or accounting firm. The training ensures the basic competencies in ethics; numeracy and accounting skills are applied in the workplace and therefore demonstrates an appropriate balance of technical, professional and ethical skills. 6b Should the programmes for various trades and occupations have different learning outcomes and durations? Yes, different industry requirements will naturally require a variety of different skills from professionals working in that industry, therefore the statutory body should consult with trades and occupations in determining the learning outcomes and the duration of the apprenticeship. 10

Each employment sector will have specific needs at each level. In accounting there are global standards as well as Irish regulations that combine to give technical learning outcomes. 6c How should the programme provide for progression beyond apprenticeship? The programme should provide accreditation and where possible allow a platform for progression into 3 rd or 4 th level education where possible, which would ultimately help strengthen the Irish workforce. The apprenticeship ACCA would promote gives the trainee a route to level 4 through an introductory certificate, to level 5 through an intermediate certificate and to level 6 through a diploma in accounting and business. The apprenticeship for accounting would enable progression into the professional qualification which provides a pathway to a recognised professional qualification for the school leaver. The full professional training for accountants, the ACCA Qualification continues to level 9 and it is important that a new apprenticeship integrates with this training to allow an apprentice to become a professional accountant. The ACCA Qualification is recognised on the Irish National Framework of Qualifications (NFQ) and is aligned to Level 9. This indicates that it is equivalent to the examinations within an Irish Masters degree, which through articulation between the frameworks, also equates to UK Masters degree level. Please refer to the Professional Bodies section on the following web page: www.nfq.ie/nfq/en/awards_in_the_framework.html#higher 6d How can learners be best prepared for potential career change in knowledge based society? The Irish economy will be most resilient to fluctuations in a knowledge-based economy by ensuring the population has fundamental transversal skills. These include finance, linguistics, IT etc. Each of these skills can be the built into the framework of every apprenticeship irrespective of sector. In this way there will be a greater return on investment for the Irish economy. 6e What transition measures/programmes, if any, are needed to prepare students to enter an apprenticeship, (a) in the case of early school leavers and (b) in the case of those with a Leaving Certificate or equivalent and (c) those with significant experience beyond school? 11

Each apprentice should receive an induction training period to ensure that they attain the basic transversal skills before they enter the work force. These can range from presentation skills to business organisations skills. A) Early school leaver: an apprentice with a basic level of skills would be advised to follow the full training provision including any transversal skills training necessary to complete the elementary parts of the apprenticeship scheme. For finance skills the introductory modules in accounting would be fundamental to any progression. B) Leaving Certificate: in this case the apprentice may be eligible to start their programme at the intermediate level. These decisions are taken on a case by case basis as the employer may prefer the apprentice to demonstrate a thorough knowledge of core skills before progressing to the next level. ACCA can accommodate this approach by through the apprentice sitting an online exam and therefore having the opportunity to demonstrate the required skills / knowledge C) Significant experience beyond school: ACCA is able to award credit for prior learning. This enables the mature person to enter apprenticeship training at the right level. For example, if a worker can demonstrate experience in a finance role, they may eligible to enter examinations at a higher level. ACCA has also developed diagnostic modules in English and maths where students can test their competency before starting the programme. 7. Assessment 7a Should the different disciplines/trades lead to awards at different levels of the national framework of qualifications? If appropriate the different disciplines and trades should be able to award the appropriate level of qualification based on outcome. In accounting there is a pathway from level 4 to level 9. ACCA feel the qualifications at levels 4, 5, and 6 are most appropriate for an apprentice. This ensures the apprentice at the end of the apprenticeship is well equipped to continue their training to become a professional accountant. 7b Should interim awards be provided for during training? Interim awards or recognition should be provided throughout the training period when significant milestones are achieved. This will act as a motivator for learners throughout the process, as well as maintaining engagement levels throughout the apprenticeship. 7b Should time spent on and off the job be more flexible where learners are assessed as meeting the final learning outcomes for the relevant discipline? No, not in ACCA s model. 12

7c How should arrangements for accreditation of prior learning be best delivered? The arrangements should be managed by the awarding body as different disciplines will have different needs and approaches. 7d How can redundant apprentices be best catered for? Redundancy is always challenging and even more so for young adults. ACCA suggests that awards are given for each level of attainment and, in that way, an apprentice who has a proven track record can demonstrate to another finance team or accountancy firm how much progress they have made. The ACCA qualifications are globally recognised and any apprentice will be more employable as a result of their documented knowledge and experience. 8. Delivery 8a What should be the appropriate balance between work based learning and education/training? There has to be a balance between gaining new knowledge and applying that knowledge in the workplace. For this reason, accounting apprenticeships work best when there are regular training days, for example one day per week for 12 weeks or block release of one week every four months. In the accounting sector the maximum off the desk training time would be approximately 20%. 8b How should this be best structured in terms of phases, duration, block or day release, e-learning etc. The phases and duration of block or day release is best accommodated on a sector by sector basis. Whilst accountancy is best understood through on the job learning this may not be the same for all trades and sectors. ACCA would ask that any prescription on delivery mode is kept at a sector level and is not applied across every apprenticeship. 8c Can employers play a greater role in delivery and how should this be done? Employers within accounting provide the environment for apprentices to apply their knowledge. Employers support apprentices in the work place, however, to ensure a consistent and meaningful apprenticeship experience, apprentices will benefit being taught the elements of accounting in a structured way. Skills learned in the workplace should reflect what is being taught in the classroom. Employers 13

are required to sign off professional experience and competencies and therefore play a crucial role in delivery. 8d Should web based learning form part of the approach and how would this be integrated into the programme? Employers, apprentices and sectors vary and no one solution will fit every situation. In accounting, e-learning works well. For example, the majority of ACCA s programmes are offered online, including the introductory, intermediate and diploma examinations. There are also several online e-learning resources available to students. ACCA, whilst meeting the need for flexibility, recognises that there are some areas of the curriculum that are better suited for face to face discussion and teaching. 9. Providers 9a What providers should deliver the off the job elements in regard to (a) technical and occupational skills (b) transversal skills In ACCA s model, there is an accredited list of approved learning providers who provide quality assured tuition to students. ACCA's Approved Learning Partner Student Tuition (ALP- st) programme gives formal recognition to leading tuition providers of the quality tuition and support that they offer to ACCA students. ACCA s Approved Learning Partners are expected to demonstrate that they meet challenging performance targets, representing global best practice in the provision of ACCA course tuition and support. ACCA s Tuition Provider Directory is an online database of Approved Learning Partners who teach any of ACCA s qualifications. Up to date information on approved learning partners for student tuition can be found at: https://portal.accaglobal.com/tpweb/faces/page/public/tuitionprovider/searchtp/xx TPQuickSearchVO1Table.jspx 9b How should this be structured? The structure should be determined by the learning provider and employer as both have a role to play to ensure that technical, occupational and transversal skills are delivered. 10. Economy 10a What is the impact of your proposals on the economy in terms of: (a) meeting Ireland s current and future skills needs 14

ACCA has recently completed research into the future of finance talent and from this research we understand that the locational strategy of finance operations is now shifting from one of cost to one of capability. The research indicates that organisations will look at the capability of the workforce and match the skills to the work. By extending the remit of apprenticeships to accountancy we can prepare the future skills needs of the country to suit location sensitive organisations with finance career propositions. (b) providing a high quality entry route for apprentices to sustainable employment The accounting apprenticeship model proposed by ACCA expands the programme outside the traditional trades, which creates greater skill diversity in the workplace. (c) costs to the State, to employers and apprentices The initial expansion of the apprenticeship scheme will incur a short term cost for a long term return on investment. The costs are shared between the state, the employer and the apprentice as each benefit from the apprenticeship. 15

Area 3. Information on other systems in Ireland including those with a significant work based learning element. Please provide information below on any programmes which you feel should be considered as part of this review in the format requested below. (The review group already has data on Skillnets and FAS Traineeships so these need not be covered). Complete a separate sheet for each type of programme. Please include programmes such as internships, or programmes of an ad hoc nature which you consider relevant). 1 Name of programme a. Certified Accounting Technician 2 Level of Certification and Certifying Body a. ACCA 3 Target Group a. School leavers, long term unemployed 4 Main Providers a. ACCA Approved Learning Partners i. BPP ii. Dublin Business School iii. Griffith College iv. Independent College 5 General disciplines/occupations covered a. Accounting including audit, tax, financial management/accounting. 6 Duration of programme in: (a) months/years Two years (b) tuition hours per annum TBC 7 Duration of programme in weeks (a) in the workplace 80% (for example 42 out of 52 weeks in a 1 year programme) (b) in education 20% including, in a training centre if necessary (for example 10 weeks as per example above) 8 How is work placement structured (e.g block release for x weeks, day release etc) 16

This should be at the discretion of the employer, in this model we suggest one day of study per four days work. 9 Who is responsible for recruitment? (providers/employers/other) Recruitment would be shared between the statutory body and employer. 10 Who funds the programme? The State is responsible for the training element of the programme as well as basic remuneration through social welfare. The employer contributes towards the salary in the form of a supplementary payment. 11 What pay or training allowances apply? See above 12 Please state why you feel this would be a good model for apprenticeship/traineeship? This model meets the needs of the economy, the employer and the apprenticeship. It makes accountancy accessible to a demographic that previously couldn t consider accountancy as a career. SASE web address www.apprenticeships.org.uk/partners/sase.aspx Scottish development www.skillsdevelopmentscotland.co.uk/our-services/modernapprenticeships/modern-apprenticeship-group/modern-apprenticeshipframeworks/accounting/ 17

Area 4. Programmes in other jurisdictions which have a significant work based learning element, and are relevant to future models of apprenticeship/traineeship in Ireland. Please give details of relevant programmes of which you are aware, if possible quoting relevant reports or website addresses. Please complete a separate sheet for each programme. 1 Country a. England 2 Name of programme a. Apprenticeship in Accounting 3 Who regulates the programme and its curriculum and how is this done? a. Financial and Legal Skills Partnership in collaboration with the National Apprenticeship Service 4 Target Group a. 16-24 year olds 5 Main Providers a. Further Education Colleges and private training providers 6 General disciplines/occupations covered a. Accounting 7 Duration of programme in (a) months/years between one and three years 8 Duration of programme in weeks (a) in the workplace see full details in question 14 (b) in education as above (c ) in a training centre as above 9 How is work placement structured (e.g block release for x weeks, day release etc) a) Day release 10 Who is responsible for recruitment? (providers/employers) a. Employers 11 Who funds the programme? a. The training is funded by the Government 12 What pay or training allowances apply? a. The minimum wage is paid by the employer 18

13 Please state why you feel this would be a good model for apprenticeship/traineeship in Ireland? a. There are elements that would work well in the Irish context as it combines application of learning within the work place as well as on the job learning. Learning becomes very relevant and is more likely to be completed. 14 Please quote any relevant sources, websites. www.apprenticeships.org.uk/types-of-apprenticeships.aspx www.skillsdevelopmentscotland.co.uk/our-services/modern-apprenticeships/ www.apprenticeships.org.uk/types-of-apprenticeships.aspx 19