The Quality Question: 5 Steps for Compliance with Ofsted's Education Inspection Framework in Higher and Degree Apprenticeship Delivery
This article builds on the Panel discussion, ‘The Quality Question: Delivering High Standards in Training and Course Delivery from Level 4 and Above’ at the Higher and Degree Apprenticeships Conference in December 2022. It is designed to provide practical insights into managing the quality assurance of degree apprenticeships in context of the regulatory environment.
Higher Education Institutions (HEIs) offering apprenticeships are subject to significantly more regulation when compared to that subjected on HEIs offering non-apprenticeship degree programmes. In April 2021 the Office for Standards in Education, Children's Services and Skills (Ofsted) was handed power to inspect all universities that offer apprenticeships, including Degree Apprenticeships at bachelors and masters levels (6 and 7).
Apprentices’ degree outcomes are also regulated by the Office for Students (OfS) at a provider level. The Education and Skills Funding Agency regulates and audits funding of apprenticeships, including through the Accountability Framework and the Quality Assurance Agency acted to externally quality assure End Point Assessments (EPAs) from 2022 until 1st April 2023 when OfS took over this role. Existing providers have had to re-register on the Register of Apprenticeship Training Providers to be able to continue to deliver training and integrated EPA providers must be registered as End Point Assessment Organisations.
This regulatory context is set against the context of significant ministerial support for apprenticeships. In March 2023 skills, apprenticeships and HE minister Rt Hon Robert Halfon MP again gave clear support to increase the number of degree apprentices.
Since 2021 universities have been preparing for their Ofsted Monitoring Visits of apprenticeships and some providers have had full inspections. Inspections follow the Education Inspection Framework (EIF), where inspectors focus on the quality of education, behaviour and attitudes, personal development, and leadership and management.
This article explores how Ofsted’s EIF has required HEIs to adapt quality assurance processes, engage in active monitoring of student progress, involve governors proactively, train staff and students so apprenticeships are understood, and ensure all requirements are in place for successful delivery through thorough approvals. I argue that adopting these practices beyond apprenticeship programmes would also benefit the wider HE student population.
Beyond the traditional approach to quality assurance and review
Leaders and managers of HEIs have had to adapt traditional quality assurance approaches to respond to the EIF. These processes used long qualitative reports which described what policies were in place and what could or should happen rather than what the situation actually was. Often the reports are not specific enough to highlight improvements to those that provide governance and oversight is not institutional. Colleagues involved in writing Self-Assessment Reports and Quality Improvement Plans know that this traditional approach is not effective for the EIF and it can result in negative Ofsted judgements as shown in some recent reports.
I’ve attended numerous conferences and events over the past year and I can see that nationally quality assurance approaches are moving more towards evidence-based, outcomes focused approaches with institutional oversight. Indeed, HEIs have had to create or adapt quality assurance processes to include observations of teaching and progress reviews, and assessment feedback sampling to ensure the requirements of the EIF are being reviewed internally.
Adopting these processes beyond apprenticeship programmes has the potential to identify and bring about more proactive changes to the student experience than traditional approaches to quality assurance.
Active monitoring of student progress
Rachel Maxwell’s recent HEPI article highlighted that the inclusion of analytics in the Teaching Excellence Framework demonstrated the direction of travel of using learner analytics to proactively support students towards the mainstream in HEIs. This involves, for example, tutors considering early indicator dashboards and at-risk data to identify early interventions.
These approaches are now much more common in HEIs than a few years ago especially with respect to predictive student analytics covering wellbeing and engagement. In HEIs I still think this is an ongoing culture change, especially with respect to ensuring responsibilities for monitoring and providing support are clear, and actions effectively resourced.
Pre-higher education tutors are used to regularly assessing progress and monitoring data to inform interventions and planning to ensure students make progress. Ofsted’s EIF makes it clear that assessment should be used to check understanding and inform teaching for degree apprenticeships also. This level of student-specific and regular monitoring has not been as common in HEIs traditionally. Thus, colleagues involved in apprenticeship delivery have had to adopt more active monitoring of student progress during teaching and learning. The timing of monitoring is therefore occurring more frequently in apprenticeship programmes and at more granular level, for example that of specific programmes and individual students.
The outcome of monitoring also shifts the focus towards HEIs providing more support to students to make progress during study rather than waiting for a summative assessment to raise an issue with an apprentices’ understanding. With the OfS regulating student outcomes for programmes beyond apprenticeships (B3) surely adopting this approach on an institution-wide basis would support students across all programme types and maximise the progress and outcomes for all students. As HEIs we should be doing this regardless of the threat of regulatory action.
Governors need institution-wide oversight
I’ve been in many meetings where HEI leaders have discussed the extent to which HEI governors (e.g. University Councils) should have oversight of apprenticeships specifically. Often the argument is about scale: why would HEIs want governors to have oversight of such part of provision in terms of student numbers?
The EIF is clear: that governors will know the strengths and weaknesses of provider’s apprenticeships, and can challenge and hold senior leaders to account for improving the quality of education. Ofsted’s monitoring reports on Leeds Beckett and Wolverhampton stated respectively: “Governance arrangements are not effective. Members of the apprenticeship board do not receive sufficient information about the apprenticeship programme. They are therefore unable to provide effective scrutiny and challenge.” and “[l]eaders must ensure that governors receive useful information about apprentices’ progress and achievements so they can hold leaders to account”.
This means that governors need training in apprenticeships so they understand what they are and how they can discharge their responsibilities. A number of institutions have assigned governors with responsibilities to oversee apprenticeships (and safeguarding and Prevent). Governors need to have more proactive governance in overseeing performance data which is provided more regularly than normal in HEIs so that the governing body can challenge senior leaders and mangers of apprenticeships specifically. This means that institutional key performance indictors (KPIs) must be in place not just for apprenticeship recruitment and achievement but also for the quality of teaching and progress reviews. For more about governance of apprenticeships see Professor Liz Cleaver’s AdvanceHE article.
Apprenticeship requirements must be understood
Apprenticeships are so different from traditional higher education programmes and have so many requirements inspected externally. HEIs have underestimated the resources required to develop, implement and operate successful apprenticeship programmes.
Senior leaders, managers, professional services staff, academics, and apprentices all need to have both initial and ongoing training to ensure that the requirements of apprenticeships are understood, so that those requirements can be met on an ongoing basis. It’s too often the case that issues have arisen because of a lack of understanding of the requirements. The University Vocational Awards Council (UVAC) provides excellent training and support in this area.
Effective approvals are key
Many HEIs are adapting programme approval processes to fit apprenticeship approvals. Taking apprenticeships through pre-existing approvals will not provide the effective scrutiny required to ensure that programmes launch successfully.
Colleagues involved in approving apprenticeships are frequently those who would normally be involved in HEI approval processes, but they often do not have the required detailed understanding of apprenticeships to ensure all requirements will be met from first launch due to the additional and specific demands of these programmes.
All aspects of an apprenticeship need to be considered by those trained to understand apprenticeships, so that approval is only given once there is assurance that everything is in place. Bespoke, integrated or separate processes may work providing that the apprenticeship requirements are considered and are reviewed by those who understand those conditions and what they mean in practice.
In addition, due to changes in apprenticeship standards programmes are likely to require re-approval more frequently than traditional provision. This means that HEI systems and processes need to be reviewed to allow for this agility. Instating an agile re-approval process will pay dividends beyond apprenticeship approvals as HEIs look to develop and approve increasing numbers of Higher Technical Qualifications, short courses and micro credentials.
Learning from quality assurance processes
Regardless of your opinions on Ofsted’s inspection methodology I’d argue that HEIs could learn from the contents of the EIF for both apprenticeship and non-apprenticeship provision. The following steps will be key to HEIs when it comes to developing robust and successful higher and degree apprenticeship programmes:
Focusing on quality assurance processes
Actively monitoring student progress
Involving governors more proactively
Training staff and students on programme requirements
Ensuring requirements are in place for successful delivery at the point of approval
With these steps, HEIs can enhance programme delivery beyond degree apprenticeships, working towards improvements for all higher education students.
About the author
Dr Graham Garforth is Head of Academic Quality & Standards at a large distance learning university where he advises and supports colleagues who are responsible for quality assuring apprenticeships. He is an educational leader, specialising in quality and standards, with over 10 years’ institution-wide leadership and management experience in post-16 and higher education settings, across curriculum design and management, staff development, quality assurance and enhancement, and compliance with external regulators/inspectors. For the past few years he has worked in universities to build apprenticeships into institutional governance and quality processes. His interest in vocational education comes from his teaching background and research interests. Views in this article are his own.
