This article originally appeared in FE News on 15 March 2019.
Think of the last time you played a board game. Monopoly? Risk? Doesn’t matter. The important thing is that when you played, there were a set of rules that everyone had to follow if they wanted to play.
Knowing the rules to a game lets you participate, and following those rules allows the game to proceed. Without the rules, nothing happens. It’s just a bunch of people sitting at a table, twiddling their thumbs.
In most areas of life, we need rules and guidelines in order to function. Without them, most of us wouldn’t know what to do.
As you can imagine, this applies to many areas of further education. One area where a set of rules is very much needed is in the External Quality Assurance (EQA) to End-Point Assessment (EPA).
Who makes the rules?
Currently, there is no single regulator of EQA of EPA in England. Instead, when developing an Apprenticeship Standard, Employer and Trailblazer groups determine which category of EQA would be best placed to deliver for their sector:
- the Institute for Apprenticeships and Technical Education,
- the Employer group,
- a professional body,
- Ofqual or QAA.
As a result, there are more than 25 EQA providers providing quality assurance services for different Apprenticeship Standards.
This sounds like a decent idea on paper. It may, for example, give professional bodies the opportunity to regulate their own sector and promote established best practice. Employers may also like the idea of a sector-specific EQA involved in the quality assurance process of their apprenticeships. However, in practice, this approach has caused many problems.
EQAs assigned to particular Apprenticeship Standards appear siloed off, playing by the rules set for their own sector. And employers are unlikely to be aware of the EQA details unless they understand a very complicated process, which makes the employer-satisfaction argument a moot point.
This approach also makes it difficult for organisations, like EPAOs, who need to work across sectors and with many EQAs while delivering EPA. Consistency is needed, and fast.
EQAs and EPAOs
Over the last two years, TQUK has delivered EPA for many different Apprenticeship Standards. As a result, we’ve interacted and collaborated with many EQAs across a range of sectors, with wildly varying experiences.
One EQA we engaged with set out to conduct their review of our services in August of last year, yet that review did not happen. After several months of following up, the review took place…in mid-December.
What’s more, the review was only a simple 90-minute on-site visit plus a desk-based review of materials and evidence submitted in August to a tight deadline. As of March 2019, we have still not received any report on that visit.
Some EQAs, however, have been more proactive, undertaking first visits, prioritising their visit schedules based on activity levels of individual EPAOs and sending reports within ten days. We have also had EQAs performing anywhere between these two extremes.
Having a common set of rules that apply to EQAs across sectors would help EQAs, too. At the moment, both EPAOs and EQAs need to prepare for visits and audits while not knowing the timelines or standards against which they’ll be judged.
There are also currently no common approaches across EQAs or other industry regulators. In other cases, EPAOs can receive contradictory advice and feedback from different EQA bodies. For instance, a professional body in one sector may outline that something is accepted industry practice, whereas Ofqual, for example, may not.
Such a situation begs the question: is Ofqual best placed to be an EQA for EPA if they can only apply a one-size-fits-all approach? And, if so, are EQAs being given clear guidance on what exactly their role and remit is?
The awarding sector provides a potentially good example to emulate. When an Awarding Organisation offers an EQA service, they produce a handbook which includes clear details of the systems and processes that the centre is expected to have in place.
This provides a standard framework against which both the Awarding Organisation and centre can work. Such a system could work in the EQA of EPAOs if the framework provides clarity and detail without room for individual interpretation.
A consistent methodology is really important to have in place because it gives EPAOs and EQAs a sense of what the rules are so that they’re not working blind.
The fragmented approach to EQA of EPA also affects the creation of high-quality and fit-for-purpose assessment plans by the Institute (previously IfA) and the Trailblazer groups.
TQUK has come across many assessment plans that are not well devised, with unclear direction, over-assessment, the timing of assessment activities and grade descriptors all being on-going issues. In many cases, EPAOs have had to bridge gaps independently to ensure quality benchmarks are being met and that apprentices are receiving a quality assessment process.
EQAs, in theory, are supposed to act as a port of call, or buffer, between EPAOs and Employer groups. If EPAOs have any questions or concerns about assessment plans, they are meant to go through the allocated EQA. Some EQAs fulfil this role well, while others do not provide clear guidance.
In some cases, it is unclear who the allocated EQAs are and no contact details are provided for EPAOs to contact.
Establishing rules outlining what is expected in this area will help EQAs and EPAOs contribute to the development of assessment plans so that mistakes aren’t repeated in the future.
The need for a more integrated approach to EQA of EPA has been recognised by the Institue. They have indicated that they are making moves to implement a new, more detailed framework for EQAs to follow and will emphasise support and guidance for EQAs and EPAOs. We eagerly await the day when there will be more standardisation between EQAs.
In the meantime, TQUK will continue to do everything we can to create a level playing field for all involved.
See you around The Hive!