Public sector apprenticeship targets: What you told us
Thanks to all who responded to our questionnaire on the Government’s proposals to introduce apprenticeship ‘targets’ in the public sector.
Thanks to all who responded to our questionnaire on the Government’s proposals to introduce apprenticeship ‘targets’ in the public sector. Your comments provided real insight into the challenges posed by this policy.
We received responses from a diverse range of clients across the public sector, including input from local authorities, NHS trusts, police bodies and fire and rescue.
After analysing your feedback we submitted a combined response to the Government, as a firm and on behalf of our clients.
The Government has pledged as a ‘key priority’ to create three million more apprenticeships in the UK by 2020 and recently announced plans to ensure that the public sector ‘plays a significant role in delivering apprenticeship growth’.
It is proposed that all public bodies with 250 or more employees in England should be subject to a minimum target of 2.3% apprenticeship starts each year. There will be a requirement to annually publish information on progress towards meeting the target.
The Government published a consultation paper inviting views on the detail of the proposals.
Your views on the issues
A clear consensus emerged on some of the questions posed in the consultation whilst on others opinion was divided or our clients called for further information or clarification from the Government. Your concerns on the key issues are summarised below.
The majority of clients who responded to our survey felt that the objective behind the proposed target – to boost apprenticeship provision in the public sector – was laudable.
However, a number of you who responded to our survey were disappointed that the consultation document did not invite discussion of the 2.3% figure and whether this is appropriate. Many of you have welcomed an opportunity to discuss whether the 2.3% target really accords with the future staffing needs of the public sector.
Our clients also expressed concern that public bodies will be impacted by two distinct policy initiatives at once: the public sector apprenticeship target and the apprenticeship levy. It was suggested that there needs to be further consultation regarding how these two initiatives will interact and/or guidance on how the public sector can best utilise levy payments towards achieving their apprenticeship recruitment targets.
A common concern was that a focus on the ‘quantity’ of apprenticeships provided by the public sector might detract from the ‘quality’ of the training provided.
One client who responded to our survey (in the fire and rescue sector) strongly felt that imposing an apprenticeship target on public sector bodies would serve to drive down standards and encourage employers to choose the lowest cost options in order to meet the target.
A number of respondents to our survey wished to stress that the focus should be on the quality of apprenticeships rather than numbers, with public sector employers being encouraged to offer higher quality, higher level apprenticeships and to work with HE institutions to identify ‘progression pathways’ for apprenticeships.
Concerns were also expressed that many organisations ‘lack the internal infrastructure to allow good quality learning to take place’ and would struggle, without additional designated support or resources, to ensure ‘consistent quality with work-based provision’.
Who should be covered by the target?
Opinion amongst our clients was divided on the question of whether the apprenticeship target should be extended to all areas of the public sector. 55% of respondents to our survey agreed with this proposition while (25%) disagreed and 20% did not know.
Some of you had serious reservations about the inclusion of NHS Trusts in the apprenticeship target. The issue of adequate supervision and mentorship was raised and concern expressed that apprenticeships are not necessarily appropriate for many NHS roles. Our clients expressed concern that imposing an apprenticeship target on NHS Trusts would create risk, as there might be insufficient capacity to supervise and develop large numbers of apprentices alongside existing junior staff.
A number of our local authority clients queried whether it is appropriate or fair to extend the target to all local authorities regardless of size or financial position. A number of local authority respondents to our survey stated that they would struggle to comply with the 2.3% target in light of reductions in government funding and the increased costs of the new national living wage. There was a suggestion that consideration should be given to the financial position of individual local authorities, with those which have recently seen significant headcount reductions potentially exempt from the target.
It was clear that a number of respondents to our survey were extremely apprehensive about the additional financial strain the apprenticeship target and levy will place on local authorities.
Should organisations be ‘grouped together’ for the purposes of the target?
The Government is considering whether certain public bodies should be ‘grouped together’ for the purposes of the target (for example ‘all local government authorities’ or ‘all NHS Trusts’). All bodies within a ‘group’ would be included (even if they employ fewer than 250 people). However it is likely that the 2.3% target would be applied to the ‘group’ as whole.
Whilst there was no clear consensus on this issue amongst respondents to our survey, a number of clients suggested that public bodies with a ‘common geography’ should be grouped together.
It was suggested that similar organisations in close proximity might be grouped (e.g. geographically adjacent local authorities). Alternatively, it might be preferable for diverse bodies sharing a common geography to be grouped together.
One NHS client suggested grouping local organisations that work towards a ‘common goal’ (for example the Council and CCG) whilst recognising that ‘logistics’ would need to be clearly agreed between ‘grouped’ bodies.
One police client felt that emergency services should also be grouped together given that there are already many requirements for either collaboration or the ‘joining up’ of centrally managed services in that sector.
How should the target be calculated?
It is proposed that the target will be calculated solely on the basis of headcount. The number of apprenticeships each year must be equivalent to 2.3% of the total workforce. So, for example, an organisation with a total headcount of 1,000 would be expected to take on 23 apprentices per year.
A majority of the clients who responded to our survey (55%) disagreed that headcount is the correct basis for the target, with one local authority client describing it as a ‘crude’ measure for calculation.
25% of the respondents to our survey felt that ‘full time equivalent/whole time equivalent’ would be a better basis. It was felt that, where large numbers of part time staff are employed, FTE will give a more accurate picture of workforce capacity. Some clients feared that using headcount as the basis for the target may result in some public bodies being expected to take on unrealistically high numbers of apprentices.
Furthermore, a number of our clients queried whether it was appropriate to calculate the target based on an organisation’s total headcount, where only a small proportion of roles or job-types within that organisation could reasonably be offered as apprenticeships. For example, one NHS Trust client suggested that the headcount figure should exclude doctors (and other roles where apprenticeships are not appropriate) and that the target should be expressed as a proportion of headcount in roles or job-types suited to vocational learning.
Given the financial pressure on many local authorities facing headcount reductions, it was suggested that it might be preferable to set the target at 2.3% of total recruitment in a particular target period. This would have the desired effect of ensuring that public bodies ‘pull their weight’ in respect of apprenticeships while avoiding the countervailing pressures on local authorities struggling with budget cuts.
Is the target period correct?
The consultation proposes that the ‘target period’ will run from 1 April to 31 March each year.
70% of respondents to our survey agreed that a 1 April to 31 March ‘target period’ was appropriate. 20% did not agree and 10% did not know. Amongst those that disagreed with this reporting period, reasons were varied.
It was suggested that it might be more sensible to align the ‘target period’ with the academic year (September to July/August) as most apprenticeships are likely to start in September when the academic year begins.
One client specifically suggested that a two or three year ‘rolling target’ might be more practical and realistic, allowing public bodies time to develop and build recruitment strategies. This would also allow for the fact that many ‘quality’ apprenticeships are two or more years long.
The consultation document suggests that BIS would be happy for businesses to ‘work towards’ a target of 2.3% by 2020. It appears that this ‘cumulative’ approach would be welcomed by many of our clients.
Reporting on progress
To ‘increase transparency’ public bodies will have a duty to publish information annually on progress towards meeting the target. This information will include:
- The number of employees that began work in the reporting period;
- The number of apprentices who began work in the reporting period;
- The number of apprenticeship starts as a percentage of the total workforce;
- The number of employees that the body has at the end of the period;
- The number of apprentices who work for the body at the end of the period; and
- The number of apprentices at the end of the period as a percentage of the total workforce.
The consultation sought views on whether it should be mandatory to provide any other information.
The clear majority view of the clients who responded to us (70%) was that employers should not be required to report any information other than that set out in the consultation.
One client suggested that information on the progress of apprentices to full time employment, education or recognised training might help the Government to assess the efficacy of the public sector target and the quality of apprenticeships offered by the public sector.
However, most respondents to our survey were keen that mandatory reporting should be kept to a minimum. A number of Respondents to our survey also stated that clear Government guidance on the reporting requirements would be welcomed.
The consultation process closed on 4 March 2016 and the Government is currently analysing public feedback. There is no clear indication as to when a formal response to the consultation can be expected or exactly when the target will come into force. However given the timescales likely to be involved in debating and passing new regulations it is unlikely that the target will be implemented sooner than September 2016. We will update you when a response to the consultation is published.
If you have any further question or comments on this issue please do not hesitate to get in touch with Louise Singh (firstname.lastname@example.org) or speak to your usual Weightmans contact.