Since the Government introduced the new Apprenticeship Levy, barely a day has gone by without a call coming through to CSA headquarters wanting further details on what it all means and how the Association can help its members use the Levy.
Part of this was prompted by our inclusion on the Register of Apprenticeship Training Providers (RoATP). This has led to a number of very exciting conversations, not only with CSA members and those working within our own specific niche within financial services, debt collection and debt purchase, but also with businesses further afield – well-known High Street names who see real value in harnessing the very specific (and niche) learning skills of the CSA. Working both with NOCN (for our Compliance Apprenticeships) and the Chartered Institute of Credit Management (for our Credit Control and Collections Apprenticeships) as our End Point Assessment Bodies, it is a powerful proposition that is already being well received.
This is where apprenticeships are particularly exciting. There is a dawn of realisation among firms, including various blue-chip organisations and even government departments, that they can use their levy to create apprenticeships in areas that have typically been under-invested.
There is also a realisation that Apprenticeships can be very broad in their scope, to take into account new initiatives from the likes of the Financial Conduct Authority (FCA) such as the Senior Managers and Certification Regime (SMCR). Brought in to replace the Approved Persons Regime, SMCR is designed to bring even greater accountability to the conduct and behaviours of individuals within a business, and ultimately reduce the likelihood of harm or detriment to the consumer. SMCR encourages a culture among staff at all levels to take personal responsibility for their actions, and firms must be able to clearly demonstrate where responsibility lies.
some levy paying employers are still cautious about the value of apprenticeships given their interpretation of some of the conditions that apprenticeship’s need to follow
Understandably, perhaps, SMCR has caused more than a little angst not only among those individuals who will now be accountable, but also among the firms responsible for ensuring those individuals have the proper training and support they need to do to do their jobs. This is where Apprenticeships can again play an important role, helping to develop staff in the context of what the new regime demands.
But as much as we are excited by the opportunities that apprenticeships present, and the interest that has so far been generated, some levy paying employers are still cautious about the value of apprenticeships given their interpretation of some of the conditions that apprenticeship’s need to follow.
A big area of confusion surrounds the requirement that 20% of an apprentices’ training must be what is called ‘off the job.’ This has led some within our industry to interpret this as being the loss of an employee for one day a week, which given the current economic challenges and uncertainties, is not an attractive proposition, especially if translated across not just one but perhaps upwards of 20 employees. But is this really the case? And what does ‘off the job’ actually mean?
Off-the-job training
Off-the-job training is defined by the Department of Education as learning which is undertaken outside of the normal day-to-day working environment and leads towards the achievement of an apprenticeship. This can include training that is delivered at the apprentice’s normal place of work but must not be delivered as part of their normal working duties.
The off-the-job training must be directly relevant to the apprenticeship framework or standard and could include: the teaching of theory (for example: lectures, role playing, simulation exercises, online learning or manufacturer training); practical training such as shadowing, mentoring, industry visits and attendance at competitions; and learning support and time spent writing assessments/assignments. What it does NOT include is training which takes place outside the apprentice’s paid working hours.
Crucially, this 20% off-the-job training requirement is measured over the course of an apprenticeship (a minimum of 12 months), and it is up to the employer and provider to decide at what point during the apprenticeship the training is best delivered.
This does not, therefore, mean ‘losing’ an employee a day a week if it does not suit the business need. It could be a proportion of every day, one day a week throughout, one week out of every five, or a proportion at the beginning, middle or end. This will depend on what is best for the organisation, and the apprentice and on the technical or theoretical requirements of the apprenticeship standard. Crucially, also, ‘off the job’ does not mean ‘off site.’It is the activity, and not the location, that determines whether the training meets the funding rules definitions. And it is neither the employee nor the government who is dictating when, where and how this training is delivered. It is up to the levy payer themselves.
For firms who have understood the importance of apprenticeships, but are nervous about the disruption that ‘off the job’ training may cause, then think again. ‘Off the job’ does not mean out of site or out of mind. The CSA has developed its apprenticeships through the direct involvement of employers who have shaped the apprenticeships to meet their business needs and crucially deliver better qualified employees that will add value to their business and bottom lines.
