Scottish Government

CONSULTATION ANALYSIS REPORT

Introduction

Following informal consultation with various interested parties, including training providers, Sector Skills Councils/Bodies, employers, and those involved in the delivery of Modern Apprenticeships ( MAs), Scottish Executive officials decided to formally consult on proposals for the future of the MA programme.

The MA consultation was launched on 15 ^th August and ended on 7 ^th November 2006. The consultation paper can be found at Annex A. The consultation was distributed to 86 organisations covering a wide range of interests. The original distribution list can be found at Annex B. 80 written responses to the consultation were received. 5 individuals responded and 75 responses were from organisations. 37 of those on the original distribution list responded to the consultation. 43 organisations who were not on the distribution list responded. This was mainly due to the efforts of the representative organisations which were contacted and who encouraged their members to reply. 21 Sector Skills Councils/Bodies ( SSC/Bs) and 22 training providers, or organisations representing training providers, responded to the consultation. A list of respondent to the consultation can be found at Annex C.

As well as the written consultation, a range organisations/groups were invited to attend a meeting or consultation event. The purpose of these events and meetings was to explore issues and give context to the consultation exercise. Officials held meetings and events with training providers, SSC/Bs, and voluntary organisations. Individuals organisations such as the Scottish Qualifications Authority ( SQA), Commission for Racial Equality, Equal Opportunities Commission and Careers Scotland also attended. Some of these organisations also sent written responses.

Officials analysed and summarised the responses to the 30 questions in the consultation paper. Not all respondents replied to every question.

The purpose of this report is to openly reflect the responses to the consultation. Throughout the analysis and summary of responses it has been the intention of officials to stay true to what has been said and include as much information as possible, representing the views of the few as well as the many respondents expressing similar views. This report is not a reflection of Ministers' opinions or an indication of the way forward.

Key Messages

• The majority of respondents agreed with the aim proposed for the MA programme. Over half the respondents also agreed that the balance of the aim should be in favour of economic development.
• The vast majority of respondents agreed that MAs should be extended to level 2 ( SCQF 5).
• Most respondents thought that the Vocational Qualification ( VQ) was the right qualification for proving competence in a job but most agreed that there should be flexibility to allow other qualifications to be used within MA frameworks.
• There was no clear cut answer on whether there were any cases where a core skill should not be included within an MA framework or included at a lower level.
• There was almost unanimous support for the principle of embedding core skills within the VQ, wherever possible.
• Most of the responses were supportive of using the Scottish Credit and Qualifications Framework ( SCQF) to credit and level MA frameworks.
• Most respondents were happy that the MA programme remained employed status.
• The majority of respondents were supportive of a minimum wage of £80 for apprentices.
• Some respondents thought current arrangements for quality management were too bureaucratic and systems orientated. However, a significant proportion also thought SQMS was adequate.
• The vast majority of respondents felt that MAs should be an all age programme.

Aim

Overall most respondents were supportive of the aim proposed in the consultation document but several suggested minor changes including the following:

• The word 'study' should be removed as this was not thought to be the correct word to use in the context of vocational training.
• The reference to 'skills shortages' should removed as there was not really a problem with skills shortages in Scotland. Some suggested replacing this with 'skills issues' or something similar.
• Some felt that more should be added about the benefits to individuals and employers.
• There should be some mention made of skills for the future.
• Some felt the aim was vague and needed to be made more explicit.

A significant majority of respondents thought that the aim achieved the necessary balance between economic development and social inclusion. Of those who disagreed, the main reason was because they felt there was too much emphasis on economic development. A number of respondents felt that there could not be two aims and a final decision should be made about whether the aim was economic development or social inclusion.

Extension of MAs to Level 2

Most people agreed that MAs should be extended to level 2 and gave the following reasons:

• There were many jobs at level 2 and in some sectors the greatest demand for training was at level 2
• This change would improve the status of level 2 training
• Some thought this would be a positive change because it would encourage more people into formal learning
• Some felt this would create more opportunities for progression from school
• This would achieve parity with the rest of the UK

The benefits of such a change were seen as helping to facilitate progression, improving uptake of MAs, improving completion rates and encouraging more people, including under represented groups, into structured learning. Of those who disagreed with the proposal, the main concern was that this would confuse employers and individuals. Although most respondents agreed that MAs should be extended to level 2, a significant number were concerned about the risk that this would devalue the MA programme.

Qualifications

There was overall support for using alternative qualifications, but also a recognition that VQs should be the default qualification when developing any MA framework. There was strong support for the VQ, but also some reservations and safeguards requested. By far the most common was a desire for the approvals process to scrutinise any proposal which did not utilise a VQ and to challenge the rationale behind using a different qualification. There was also a desire from a number of respondents to limit alternative qualifications to those approved by the SQA accreditation unit. It was felt that this would ensure there was an element of quality assurance built into the process and reduce the potential for the MA brand to become devalued. There were a number of respondents who felt that MA frameworks should continue only to use VQs. The most common reason for this was due to the potential to create confusion with employers, schools, colleges, parents and future prospective apprentices.

Use of the Scottish Credit & Qualification Framework ( SCQF)

Most of the responses were supportive of using the SCQF to credit and level MA frameworks. However, there were some uncertainties and questions around how this would work in practice - how much this would cost, as well as some technical issues. There were also some concerns about how the SCQF would link to the English and to the European qualifications frameworks.

Core Skills

In the majority of responses, core skills were seen as extremely important - being essential to employment and employability. It was also felt that core skills improved the performance of the individual in their existing job as well as helping them in other posts, not necessarily within the sector currently employing them. Core skills were also thought to help employers ensure they had a skilled workforce.

There was no clear steer from the consultation responses on whether there were occasions when core skills might not be used or included within frameworks at a lower level. It should also be noted that a significant number of respondents did not answer this question.

Some respondents were in favour of the level of core skills being set by the relevant SSC and appropriate to the level required by the job. This would mean some core skills being dropped, or being included at a lower level, on occasion. Numeracy and IT were the most common core skills cited as either inappropriate to the sector or set at too high a level. There were also some respondents who, although in favour of change, thought it would be best to wait until Scottish Executive Education Department had completed its review of core skills.

A significant proportion of respondents thought core skills should remain as they were and should only be lowered for MAs at level 2 - assuming this proposal was taken forward.

There was almost unanimous support for embedding core skills within the VQ with the following comments being the most common:

• Sometimes difficult to assess but should be happening as a matter of course
• Fairest way to test competence and less demeaning for older MAs
• Would save duplication in many cases
• If the appropriate VQ is chosen then the core skills should follow automatically

Of those who were in favour, some felt there was a need to ensure that the individual could understand where the core skills were relevant to their job. Others commented that if core skills were achieved fully in schools there should be little need for them to be delivered as part of the MA for younger apprentices.

Most respondents felt the core skills mapping exercise (for embedded core skills) should be audited or checked. Most suggested that the Scottish Qualifications Authority ( SQA) or an awarding body carry out this function.

Employed Status

There was overwhelming support for a fully employed status MA programme. It was felt that this offered the best option for vocational training in a work based environment. It was also suggested that this increased commitment from employers and provided more structured support for the individual.

There was, however, concern that provision for people who were not yet 'work-ready' continued. Some also suggested there may be a need for flexibility within the programme where legislation prohibits certain age groups from doing certain types of work, but who could still be working for a level 2 or 3 from age 16. Unfortunately there were no examples of these types of jobs.

Setting a Minimum Wage

There was strong support for introducing £80 per week as a minimum level of pay for MAs to bring Scotland in line with England & Wales. There were concerns that £80 was still too low and that employers would perhaps use this as an excuse to reduce their current rates of pay (given that most pay more than £80). A significant number of those who agreed with the £80 rate, thought that apprentices should be receiving the national minimum wage but recognised this was a reserved matter and were content to agree to £80 at present. There was also a slight concern that this rate would be encouraged as opposed to mandatory.

There were a range of opinions on how a minimum wage could be policed but strong support for this to be part of the contract, funding, and/or the registration and certification process.

Quality

By far, the main comment about current arrangements for quality management was that they were too systems orientated, bureaucratic and time consuming. However, a significant number (mainly training providers) commented that the current arrangements were adequate - only minor amendments were suggested, in some cases.

When asked how quality management of the programme could be improved, the majority of respondents commented that some type of inspection or external audit was required. There was a general feeling that, although self assessment was a useful tool for training providers, external audit ensured a robust system which would be respected by those involved in the programme. Some suggested that HMIE could take on this role while others suggested the system used in England (Adult Learning Inspectorate). Others felt this was a role which the Enterprise Networks could carry out. One respondent commented that too many under-performing training providers had retained contracts to deliver MAs under the current Scottish Quality Management System ( SQMS). This respondent felt that those companies which had invested in improving quality had not been rewarded adequately. It was also felt that a reduction in bureaucracy and less emphasis on procedures and record keeping would help improve the existing quality management system ( SQMS)

Age

The vast majority of respondents supported the proposal to retain the all age element of the MA programme. Most commented that there was a need to reflect Scotland's aging population and for workers to retrain throughout their career. There were also some comments in relation to encouraging those who were economically inactive to re-enter the workforce through an MA which was felt to be less daunting due to the tailored training associated within an MA framework. A minority felt that MAs should only be aimed at young people.

Ancillary Matters :-

Fit with Other Policies

The over-riding theme within the comments put forward here was based on better careers advice within schools. It was recognised that the SCQF had an essential role to play in assisting to gain parity of esteem with traditional academic qualifications and routes, but in order to be effective this had to be understood by those providing advice on the front line. It was also felt that Skills for Work courses provided an excellent opportunity to make a demonstrable link into the school curriculum, but it was felt that not enough was being done to stop repeat learning for the candidate.

Under-represented Groups

Most respondents offered suggestions on how participation of under-represented groups within the MA programme could be increased. The vast majority thought better general promotion of the MA programme was required. Some thought specific promotion or marketing which targeted under-represented groups was needed. Many also suggested better general careers advice at school would help. Several thought extending MAs to level 2 would enable easier access for under-represented groups and a similar number said more funding in general was needed. This was on the basis that more MAs available for everyone would increase uptake across all groups.

Guidance Materials

The majority of respondents agreed that a Blueprint document should be developed. They felt that it would be a good idea for the following reasons:-

• It would give clarity of understanding and expectations
• It would be good to have 'one' document
• It would allow for consistency between/across frameworks

Several respondents did comment, however, that we should be careful not to make the Blueprint too prescriptive and to update the Blueprint regularly.

Employer Involvement

Many respondents thought the key to encouraging greater employer involvement in MAs would be to market and promote the benefits of MAs better to employers. Some also thought that employers were not aware of the funding available for MAs and that increased awareness would encourage more to engage with the programme. Several thought that we should celebrate the successes of the programme and the achievement of employers and apprentices as a way of encouraging employers to see the benefits.

There was some concern about whether the content of MA frameworks truly reflected the needs of employers. Some questioned whether SSCs were performing the role of representing employers' needs effectively. A significant proportion of respondents also suggested more funding should be provided for MAs - either making them available to adults in more sectors or suggesting higher contribution rates. Some respondents thought more guidance should be available to employers - either written guidance or in the form of support from advisors. Several thought a mentoring programme for employers would be helpful.

Additional Comments

The majority of responses to this question have already been covered by previous questions. The following gives a summary of issues which were not raised elsewhere:-

• We should have more parity with England regarding terminology.
• Scottish Enterprise should not be responsible for delivering MAs - this should be down to SSCs.
• MAs are invaluable in supporting people of all ages gain a recognised qualification, giving them self belief and self worth and businesses grow and develop.
• It is essential to ensure good induction to the MA .
• We should consider more flexible delivery models for very small companies, rural areas and those in seasonal employment.
• Need to make a decision soon - consultation period has been too long.
• There should be genuine partnership working between organisations delivering/involved in MAs - this will benefit the employer and the apprentice ultimately.
• The needs of the employer should be given full consideration

Conclusion

Ministers will now consider all the responses and reach decisions on the future of the Modern Apprenticeship programme in due course.