Now here is a classic example of what happens when a policy is not properly thought through.
In the old days, the quality of training was judged by measuring the inputs – how much time did each learner spend on their learning? Learning was further broken down into “guided” learning, where a teacher was physically present, and “other” learning, such as self study. The former was regarded as preferable – not because it was better but because it was seen as easier to verify.
People who have spent longer than I have in vocational training tell me that this spawned the creation of reams of paper timesheets, each bearing details of hours and minutes spent on guided learning and religiously signed by learners and assessors. These timesheets would keep auditors happy for hours, concentrating on whether they were internally consistent and ignoring the fact that they were often wholly fictional.
This attitude lives on in the approach to CPD taken by organisations such as IfL, which require annual declarations of compliance which can be sample checked by yet more auditors in order to verify that someone attended a course at a particular time and place. What these records cannot do, of course, is tell the auditors whether the person was concentrating, or even awake, at the time.
Elsewhere, however, I thought that the old fashioned input approach was history, and that the world had now moved on to measuring the quality of the output – what learners actually know, and what they can do. The concept of “guided” learning is, in any event, hopelessly outdated in the age of e-learning and virtual classrooms – and although log-in records are much less easy to fabricate than paper timesheets, they still don’t tell you what was happening in the learner’s head while they were logged in.
And then came the ASCL Act 2009 (the Act), which introduced a minimum guided learning hours requirement of 280 hours and empowered sector Skills Councils to set higher requirements for individual frameworks. And the whole timesheet industry looked like kicking off again.
To be fair, the problem was not in the Act, but in the guidance which was issued with it. Although this made it clear that guided learning could encompass a range of modern methods which didn’t require a teacher’s physical presence, it was silent about the records of guided learning which providers would have to keep and which auditors would expect to see.
Crucially, the guidance failed to make it clear that, in borrowing the 280 hours which the 2008 Education and Skills Act (the 2008 Act) had laid down as an entitlement for under 19s, the Act had also borrowed the concept of how guided learning hours can be acquired. Section 9(2)(b) of the 2008 Act says (my italics)
For the purposes of this Part, a person participates in a particular number of hours of guided learning by—
(a) participating in actual guided learning for that number of hours, or
(b) completing a course or courses which can reasonably be expected to be adequate to enable persons completing it or them to achieve any standard required to attain an accredited qualification to which that number of hours of guided learning has been assigned.
In other words: if, in the course of an apprenticeship, the learner completes a qualification to which at least the required number of GLH has been assigned, evidence of that qualification is definitive evidence of compliance with the GLH requirements. Recording of individual hours for the specific purpose of demonstrating compliance is therefore superfluous – although in a college, for example, there may well be other, internal, reasons for doing so.
After some prompting, the guidance has been changed to make it quite clear that providers are not expected to maintain time records of guided learning and that SFA auditors will not be examining this aspect. Providers do, however, have to prepare a learning plan for each learner, indicating how they propose to deliver the required number of hours – whether the minimum of 280 or the higher figure for the individual framework.
As David Way, the SFA’s executive director of apprenticeships, confirmed to me in a recent email:
“if a learner completes a qualification within a framework and is awarded the qualification by the awarding organisation, then for the purposes of SASE compliance they will have met the qualification GLH as stated in the framework regardless of whether they actually undertook the GLH assigned to the qualification”.
So common sense has prevailed? Well, not quite. At least one sector skills council, CWDC, does not yet seem to be in the loop. If an apprentice completes in less than the average expected time, CWDC will refuse to issue a completion certificate unless the provider supplies evidence that they have completed the required number of GLH.
Two key skills questions for you:
If a qualification certificate has to be submitted with every application, and this certificate provides definitive evidence that the GLH requirements have been met, what additional evidence is required to show that the GLH requirements have been met?
2. Application of number
If all claims below the average completion time are to be rejected, what percentage of claims would you expect to be accepted?
The extraordinary idea that a learner should not be allowed to qualify more quickly than the average is not only based on a total misunderstanding of averages, it is also mad. There are at least three reasons why a learner might complete more rapidly than others:
(a) The provider has cut corners on quality
(b) The learner has prior experience or knowledge which gave them a head start
(c) The learner was more intelligent/committed, and/or the provider was better/more efficient than others
You do not deal with these situations in the same way, by forcing all learners to take the same time. In the first case, you find out which providers are offering (or routinely delivering) guaranteed completions of a level 3 diploma in a few months, and setting Ofsted or the awarding organisation loose on them. The SFA already deals with the second case by imposing a funding discount, so that providers cannot claim thousands of pounds merely for accrediting someone’s existing skills: but it doesn’t penalise the apprentice. And the apprentice or provider in the third case would normally be seen (except perhaps by a diehard proponent of the Chinese Cultural Revolution) as someone to be applauded, not held back.
Watch this space.