Consultation on the Scottish Government response to the introduction of the UK Apprenticeship Levy

7. Additional Suggestions and Other Comments

7.1. This section presents the findings relating to Question 6, which asked:

"Are there any additional suggestions on how Apprenticeship Levy funding might be used?"

7.2. A large proportion of respondents (80%) made comments at Question 6. Some of these related specifically to the material in questions 1-5, and have been included there. Others are discussed below, along with additional comments made by respondents about issues which were not the subject of a specific question.

Additional suggestions - overall themes

7.3. It is clear from the findings of the analysis of questions 1-5 that a number of recurrent themes and suggestions have emerged throughout. Although the relative emphasis and detailed comments varied according to the issue under consideration, there were a number of broad common themes.

7.4. These provided the focus for many of the additional comments and suggestions made at Question 6 about how the Apprenticeship Levy funding might be used. Respondents' comments focused on:

• The overall approach to the use of Levy funding.
• Specific developments and suggestions to promote learning, training, skills development and employment.
• Developments in specific sectors / subject areas.
• Developments for specific groups.
• Types of funding arrangements.

7.5. Each of these themes was mentioned by many respondents who addressed Question 6 (always at least 1 in 6, and up to around a third for some themes).

7.6. It is important to note, however, that, as respondents as a whole were not asked for their views of these issues specifically, they are indicative only of the most common themes, rather than representing a majority view.

7.7. Within each of the overall themes, it should be borne in mind that specific suggestions were often mentioned by a small number (or sometimes one) respondent. The purpose of Question 6, however was to identify a range of additional suggestions, rather than provide a "weighting" of views (which would have required a "closed" question).

7.8. It should also be noted that, while it is impossible, in a summary report, to provide a detailed account of each individual additional point made, further information is contained within the individual responses, which are available on the Scottish Government website.

The overall approach to the use of funding

7.9. Many respondents commented on the overall approach to the use of Levy funding. The main issues raised related to identifying key principles and highlighting the overall purpose of the funding.

Key principles

7.10. Many respondents reiterated the importance of some key principles which they considered should guide the overall approach to the use of Apprenticeship Levy funding.

7.11. Among these, the general need to promote quality was mentioned frequently, with comments including that there should be a focus on recognised and approved training programmes, standards and quality control.

7.12. A further common recurrent principle was the need to ensure a flexible approach to:

• Access to, and use of the funding by employers.
• Delivery models.
• Criteria ( e.g. age and previous attainment).
• Potential for spending in different locations ( e.g. cross-border spending; addressing local needs).

7.13. The importance of meeting the needs and demands of employers and the Scottish economy was a further frequent theme throughout. Comments included the importance of meeting the needs of all sizes and sectors of employers (including large employers and SMEs) and responding to the needs of local areas. Some suggestions were made about a need to address strategically important sectors, and to support other areas of need and skill shortages. A few respondents stated that the funding must add value for employers.

7.14. The need for joint working, collaboration and partnership was a further common theme. Comments included the need for further engagement and input from employers and joint working between: employers in all sectors (particularly Levy payers); training providers in all sectors; professional bodies and trades unions; and the Scottish Government / SDS. A few respondents mentioned a need for collaboration between the Scottish and UK Governments. A small number suggested that trainees should help shape developments, and that provision should meet their needs.

7.15. A further common cross-cutting issue was the need for coherence with systems in other parts of the UK. Many respondents mentioned the importance of this, particularly for employers operating UK-wide. An issue raised frequently was the need for employers to be able to spend across borders and to develop UK-wide programmes to meet their needs. Some respondents also mentioned a need for clarity and simplicity in the arrangements.

7.16. The provision of fairness, equality and social justice was another cross-cutting theme mentioned by several respondents. This was seen to relate, for example, to: availability of the funding for different employers and sectors; provision of opportunities for all of those requiring training, including under-represented groups; the promotion of workforce diversity and inclusion; and the provision of fair work principles and pay.

7.17. Several respondents mentioned that the use of Levy funding must be consistent with wider policy work, existing provisions and funding streams (including: employer provisions; employability support; existing levies etc.).

7.18. Further comments were made about the need for a coherent overall approach and clear pathways. There was also seen to be a need for: simplicity (and minimal bureaucracy); transparency; cost-effectiveness and value for money. A small number of respondents stated that the revenues received from the Levy should be published.

The overall purpose of the funding

7.19. Many comments were also made about the overall purpose of the funding. A number of respondents reiterated their support for the use of Levy funding to promote the developments mentioned in previous sections ( MAs; GLAs; a flexible skills fund; FAs; and work to improve access to employment.

7.20. While some of the ways in which the Levy funding could be used to support specific developments in these areas have been highlighted in the relevant sections, several respondents suggested additional costs which could be met to enable access to such learning, training and employment. These included that Levy funding could be used for:

• Wage subsidies and incentives to employers ( e.g. contribution to wage costs; increased wages for trainees [ e.g. to at least the National Living Wage]; expansion of the Employer Recruitment Incentive [ ERI]).
• Design, development and management of learning and training.
• Pre-selection, marketing and recruitment costs.
• Practical costs relating to individuals' employment or training ( e.g. Protecting Vulnerable Groups [ PVG] applications; special clothing or equipment; travel and subsistence; qualification costs; membership of relevant bodies; reasonable adjustments).
• Administrative costs to support learning and training.
• In-house infrastructure ( e.g. staff supervisory costs; materials; building maintenance).

Specific developments to promote learning, training, skills development and employment

7.21. A further common theme at Question 6 was the identification of specific developments to promote learning, training, skills development and employment (across different forms of provision).

7.22. Suggestions were made relating to:

• Standards.
• Certification and qualifications.
• Specific forms of training.
• Training delivery.
• Awareness raising and promotion.
• Strategy and infrastructure for learning and training.
• Research and innovation.

7.23. Some respondents mentioned the general need to use Apprenticeship Levy funding in these areas, and many gave detailed reasons for their suggestions. These generally related to the benefits cited in previous sections.

7.24. Although these will not be reiterated in detail here, these cross-cutting benefits related to the view that the proposed uses of Levy funding would help to: meet the needs of employers, sectors and the Scottish economy; meet the needs of individuals and specific groups; promote equality; address gaps in current provision; and support the overall policy approach.

7.25. Many specific suggestions were made about uses of Levy funding, or further developments required. These are presented below.

Standards

7.26. Suggested uses of Levy funding, or developments relating to standards included:

• Development of a network of training providers.
• Assessment, registration, regulation and inspection of training providers.
• Auditing of provision.
• Maintenance, review, revision and development of National Occupational Standards ( NOS).
• Development of coherent standards ( e.g. through a single body with UK-wide oversight of standards; piloting and assessing the relevance and applicability of Trailblazer standards in Scotland; and identifying how different training standards equate).
• Development of a new "quality mark" for apprenticeships.
• Regular reviews of standards.
• Ensuring a mechanism to take on the role of the Institute of Apprenticeships in Scotland.

Certification / qualifications

7.27. Suggested uses of Levy funding, or developments relating to certification and qualification included:

• Development of shorter qualifications ( e.g. Professional Development Awards [ PDAs]).
• Scottish Vocational Qualifications ( SVQs) not currently on the framework.
• HNCs and HNDs linked to skills needs / gaps.
• Preparation for professional qualification, and the Technical Report Route.
• Mandatory qualifications for particular employers.
• Development and accreditation of suitable industry qualifications and "in-house" programmes.
• Development of "general skills products / qualifications at different levels.

Specific forms and models of training

7.28. Suggested uses of Levy funding, or developments relating to specific forms of training included:

• Innovative training models ( e.g. shared apprentice schemes; joint training).
• Industry, profession or organisation-specific training.
• Pre-apprenticeship training and pre-employment / work-readiness provision.
• Further and higher education training and qualifications across sectors.
• Development of apprenticeships ( e.g. the design of new MA frameworks; the inclusion of different levels, sectors, subjects; lengths and types of apprenticeships).
• Post-apprenticeship training and in-work support.
• Jobs with training.
• Internships and work placements.
• Training for transition to employment or full employment ( e.g. further funding for the Employability Fund).
• Employers' internal training programmes.
• Re-training for existing staff in new disciplines.
• Increased provision and quality of work experience at a range of stages.
• Additional off-the-job training.
• A skills development programme (similar to the Adult Skills Budget).

Training delivery

7.29. Suggested uses of Levy funding, or developments relating to training delivery included:

• Support to FE/ HE to provide relevant qualifications and learning, and to increase places ( e.g. in subjects with high delivery costs).
• Training and support for employers and assessors ( e.g. training and support for managers and trainers; development of "communities of practice"; funding for dedicated trainers).
• A resource bank for training providers (and availability of core material online).
• Increased use of IT and online methods ( e.g. online and distance learning; online assessment development; community digital skills building; and pilot projects).

Information and support

7.30. Suggested uses of Levy funding, or developments relating to information and support included:

• Advice to trainees / employees on options at all stages ( e.g. careers advice in schools; careers fairs and careers guidance [including via websites]; job shops; employer initiatives).
• Provision to enable individuals to choose their own learning.
• Mentoring and coaching.
• "Buddy system" / work shadowing schemes for specialist posts.
• Workplace support and pastoral care ( e.g. for apprentices; young people).
• Streamlining support and information to individuals and employers ( e.g. national information; "one-stop shop").
• Support and information to specific groups of individuals and to employers in particular sectors (see below).

Awareness raising and promotion

7.31. Suggested uses of Levy funding, or developments relating to awareness raising and promotion included:

• Work to improve understanding of vocational learning and training among supporting organisations and staff ( e.g. schools; careers advisors).
• General promotion of vocational pathways as a good quality option, and public awareness raising ( e.g. promotional campaigns; events; improved information to trainees and employers; development of a "brand"; Scottish Government leading by example).
• Outreach programmes.
• Programmes to broker provision.
• Advertising and marketing opportunities ( e.g. exhibitions; open days; an app; web page; digital apprenticeship service; local employer marketing).
• Mechanisms to share examples of good practice in learning and training ( e.g. workshops; workgroups; dissemination of information; improved communication).

Strategy and infrastructure for learning and training

7.32. Suggested uses of Levy funding, or developments relating to the strategy and infrastructure for learning, training and skills development included:

• Supporting DYW Boards and Regional Groups.
• Strategic projects relating to the DYW agenda.
• A structure for the co-ordination of work-based learning.
• Skills development / innovation partnerships.
• Implementation of Skills Investment Plans.
• Links and partnerships between businesses / industry, education and training providers.
• Establishment and development of industry / sector representative or umbrella bodies, and mechanisms for links to these.
• Exploration of co-investment; co-funding and shared models.
• Development of Regional Skills Hubs.
• Development of "skills academies" ( e.g. Small and Micro Business; regional skills).
• Consultation with employers.
• Representation and involvement of trainees.
• Governance structures for the administration of Levy funding.

Research and innovation

7.33. Suggested uses of Levy funding, or developments relating to research and innovation included:

• Enterprise Innovation Partnerships and joint training for new ventures.
• An Innovation Fund.
• A "Transferable Talent Bank" focusing on innovation and technology.
• Core skills and local needs mapping and other improvements to intelligence.
• Further work on Regional Skills Investment Plans.
• Information-gathering on take-up of opportunities ( e.g. by specific groups).
• Development of a small group of industry experts to consider the evidence base.
• Piloting of new programmes.
• Development of new markets.

Developments in specific sectors / subject areas

7.34. As has been the case at individual questions, a further common area for additional comments was the use of the Levy funding to promote developments in specific sectors or subject areas.

Sectoral needs

7.35. Several respondents made reference to using Levy funding to address learning and training requirements in a particular sector, or specific issues affecting a sector.

7.36. Those mentioned most frequently (although by small numbers in each case) were: engineering and construction; health and social care; public sector (particularly local authorities); science and technology (including IT and digital); and the third sector (and individuals and communities supported by third sector organisations).

7.37. Many other sectors were also highlighted, as was the need to support developments across a wide range of sectors and types of employer (including SMEs).

7.38. Suggested uses of Levy funding, or developments relating to support for specific sectors included:

• Skills development and the provision of learning and training to meet the range of needs identified in particular sectors (including in "supply chain" and "supporter" employers).
• Sector-specific research to establish learning and training needs and barriers.
• Review of funding to identify gaps for particular sectors.
• Capacity-building relating to the provision of learning and training.
• Implementation of skills development measures identified in sectoral strategies and plans.
• Support to develop and provide relevant programmes and qualifications to meet sectoral needs (including the extension of existing programmes).
• Development and expansion of existing initiatives.
• Development of induction support packs for specific sectors.
• Incentives for particular sectors / employers, and work to increase take-up of provision.

Particular subjects

7.39. Some of the specific subject areas for skills development mentioned included:

• Management and leadership skills.
• STEM skills (including IT and digital skills).
• Coaching and mentoring.
• "Soft" skills.
• Organisation-specific skills (with a variety mentioned).

7.40. Some respondents highlighted particular roles within their own sector for which Levy funding could help to address gaps in learning and training.

7.41. Suggested uses of Levy funding, or developments relating to support for particular subjects included:

• Development and provision of learning and training in relevant subject areas (including preparatory work in schools).
• Development and provision of core skills ( e.g. digital skills; "life" and employment skills) within learning and training.
• Development and provision of learning and training relevant to specific roles within sectors.
• Promotion of specific subjects.

Developments for specific groups

7.42. Many respondents made suggestions about the use of Apprenticeship Levy funding to promote equality, and to reduce inequalities, both generally and for specific groups.

Promotion of equality

7.43. Suggested uses of Levy funding, or developments to promote general equality included:

• Equality assessment of provision for accessibility.
• Development of inclusive processes and improved access to learning, training and employment.
• Development of opportunities at a range of different levels.
• Mapping of equalities activities and preparation of local action plans.
• Further reporting on equalities issues.
• Extending employability support for those facing barriers to employment.
• Development of a Quality and Access Fund for apprenticeships.
• A flexible fund for social firms and support for entrepreneurs.
• Enhancing an employers' Equality Action Fund or similar.
• Developing equality interventions in schools.
• Greater engagement with specialist providers ( e.g. Community Jobs Scotland [ CJS] employers; disability specialists).

Meeting the needs of specific groups

7.44. Suggestions were also made about particular developments, or uses of Apprenticeship Levy funding to meet the needs of specific groups. Those groups mentioned most frequently were: older people; women; and disabled people (including people with learning difficulties).

7.45. Suggestions were also made relating to addressing the needs of a number of other groups experiencing disadvantage or barriers to learning, training, skills development and employment. These included, for example: BME people; people from "chaotic" backgrounds; people unemployed for a long period; low-paid workers and those working in "non-traditional" ways; people in rural areas; young carers; and care experienced young people.

7.46. Suggested uses of Levy funding, or developments to meet the needs of specific groups included:

• Specific initiatives and programmes to deliver tailored advice, skills and opportunities for people from under-represented groups.
• Incentives to employers and / or trainees, to target particular groups or meet additional costs.
• Pro-active recruitment initiatives.
• Promotion of awareness among employers of issues for specific groups.
• Increased funding for older learners / trainees (and work to enable all ages to benefit from the funding).
• Provision of in-work support ( e.g. for people with learning disabilities; people working in non-traditional roles in gender segregated areas; returners to work).
• Supported routes to self-employment.
• Use of a "key worker" model or similar to increase individuals' capacity to engage with opportunities on offer.
• Gender-balance initiatives and work to tackle occupational segregation ( e.g. pilot work in "non-traditional" areas).
• Support for learners to benefit from mobility programmes.
• Grants for specialist equipment ( e.g. for visually impaired people).
• Accredited volunteer training and associated expenses.

Types of funding arrangements

7.47. In addition to all of these suggested developments or uses of funding, many respondents made additional comments on actual funding arrangements for the use of the Apprenticeship Levy. Comments related to:

• Beneficiaries of the funding.
• Means of use and distribution of the funding.

Beneficiaries of the funding

7.48. Many respondents made further comments about the potential beneficiaries of the Apprenticeship Levy funding, and the most common issue raised was the need for Levy-paying employers to benefit from this. Comments included that:

• Levy-paying employers should have their funding returned to them (in full, in the view of some respondents; or an agreed portion in the view of others).
• Levy-paying employers should have first call on the funding.
• The money paid by a particular sector should remain in that sector, to meet employers' and sectoral requirements.
• Levy-paying employers should have direct access to the funding ( e.g. rather than through a third party).

7.49. As noted previously, comments were also made at various points in the consultation about the need for the funding to be available to employers not paying the Levy. Several respondents stated that some of the funding should be passed to "supply chain" employers (and those employers addressing the needs of a particular sector) and SMEs generally.

7.50. Suggestions included the general view that supply chain employers should be able to benefit from the resources, while some stated that Levy-payers themselves should be able to share their Levy funding with, or deploy unused funds or underspend, to their own supply chain employers or smaller organisations in their sector. A few suggested that this should exceed the UK Government's commitment of 10% of an employer's Levy funds.

7.51. One respondent suggested that, where the funding is not used by a Levy-payer within a reasonable time, it should be re-invested to smaller employers and / or charitable organisations. Several respondents mentioned more generally the need for funding to be provided to small employers, and for the needs of SMEs to be taken into account in the distribution of the funding. Some stated that Levy-payers should advise on this, or that it should be guided by the skills needs in a sector.

Means of use

7.52. A number of comments were also made on the means of use of Levy funding. A common issue was the need for employers to have flexibility to use the funding in the way most relevant to their business or sectoral needs.

7.53. Additional suggestions included that there should be:

• Ring-fenced funding for specific employers or sectors.
• A grant allocation directly to Levy-paying employers.
• Ring-fenced funding for specific purposes or to address the needs of particular groups.
• Grant funding for specific initiatives.

7.54. Other comments and suggestions relating to the means of use of funding (by small numbers of respondents in each case) included that:

• The amount of the Levy fund that can be spent on anything other than training and assessment ( e.g. overheads and supporting activities) should be capped.
• Funding should recognise those with a track record and commitment to training and those with specific expertise required.
• There should be a minimum period before employers' funds expire.
• The digital account method should be used to allocate funds.

7.55. A few respondents proposed specific models. One, for example, proposed a detailed model which would combine the Apprenticeship Levy funding with an industry levy. Another suggested a national approach for their own sector, with the funds which are collected from that sector being managed through a national body.

7.56. A few respondents suggested that there should be a forum or board ( e.g. an employer-led board; a national partnership forum; or an expert group) to consider and / or manage the delivery of the Levy funding. One respondent suggested that there should be a review of "forfeited funds".

7.57. Some respondents reiterated the view that the Levy funding should not be used to replace current funding, and should not be seen as an additional tax. A few stated that current arrangements ( e.g. those provided by local authorities) should be protected.

Other comments

7.58. Many respondents made other comments which were not covered by specific questions. These related to the following broad themes:

• Current issues and concerns.
• Additional implementation suggestions.
• Comments on the consultation.
• Information about the respondent.

Current issues and concerns

7.59. Many respondents mentioned current issues or concerns. Among these, the most common were about the impact of the Levy itself. Some made general comments about this, while others raised specific concerns. These included concerns about the cost to employers, and a potential lack of benefit, or negative impact ( e.g. on existing levies, other funding or training provision).

7.60. Concerns were also raised about the perceived short timescale for implementation of the Levy and many comments were also made about a lack of clarity about the operation of the Levy in Scotland. Further concerns were raised about: loss of control of funding; potential disparities in implementation across the UK; and uncertainty about arrangements.

7.61. Comments were also made about other current concerns, such as: insufficiency of current training to address the needs highlighted; low pay for trainees; the impact of the UK's vote to leave the EU; and current economic and funding pressures.

Additional implementation suggestions

7.62. Some respondents made a small number of additional suggestions about the implementation of the Levy, including that there should be:

• Governance and infrastructure arrangements.
• Clear guidance.
• Information on a range of issues in Scotland ( e.g. the distribution of funding; administration and access to resources; and cross-border arrangements).
• An implementation timetable.
• Continuing input from the Scottish Government to UK developments ( e.g. to ensure representation of Scottish issues and views; and to monitor implementation in England and learn lessons from experiences there).

7.63. Several respondents expressed the view that the introduction of the Levy should be postponed (with some stating that this should be pushed back to April 2018). A few suggested specific exemptions. One stated that there should be a further round of consultation with employers once more details are available about the distribution.

7.64. Several respondents expressed a willingness to be involved in future work, and some mentioned specific ways in which they believed they could have an input.

Comments on the consultation

7.65. Many comments were also made on the consultation, most commonly welcoming the opportunity to comment on the issues. Several respondents gave details of the nature of their response ( e.g. how it was generated; whose views were represented; links to, or support for another response; and how they addressed the questions).

7.66. A few respondents raised concerns about the actual consultation process, including:

• A lack of detailed information in the consultation (including costs of proposals).
• Lack of time to respond ( e.g. with concurrent UK Government consultations).
• Issues relating to the nature of specific questions.

Information about the respondent

7.67. Many respondents provided additional (often detailed) information about their own organisation. Common themes included.

• The nature of the organisation, aims and objectives, and focus of their work.
• Their size, geographical area and contribution to the Scottish economy.
• Their expertise and involvement in learning, training, skills development and employability policy and / or practice.

7.68. Further details of all of these issues are available in the individual responses.

7.69. All of the material summarised in this report, along with the detailed material within the responses, will help to inform the Scottish Government's consideration of the way forward.