Confidentiality & Data Protection
The Department may make individual responses available on public request, in accordance with the Code of Practice on Access to Government Information.
Please read this question carefully before you start responding to this consultation.
The information you provide in response to this consultation, including personal information, may be subject to publication or release to other parties. If you do not want your response published or released then make sure you tick the appropriate box.
X Yes, I would like you to publish or release my response
No , I don’t want you to publish or release my response
The closing date for this consultation is 14 th
August 2014
Name: David Pincott
Organisation (if applicable): BT
Address: A5, BT Centre, 81 Newgate Street LONDON EC1A 7AJ
Please return completed forms to:
Traineeships.CONSULTATION@education.gsi.gov.uk
Alternatively, you can send them to: Sue Ruck, Pre-employment & Basic Skills Unit,
Department of Business, Innovation and Skills, 2 St Paul’s Place, Sheffield S1 2FJ.
Tel: 0114 207 5255
Please tick a box in the list of options below that best describes you as a respondent to this consultation.
Representative organisation/trade body
Independent Training Provider
College
Awarding Organisation
School

x
Charity or social enterprise
Individual
Legal representative
Local Authority
Other public sector body
Direct Grant Employer*
Large business (over 250 staff)
Medium business (50-250 staff)
Small business (10-49 staff)
Micro business (up to 9 staff)
Trade union or staff association
Professional body
Other (please describe)
* The term ‘Direct Grant Employers’ refers to employers that receive funding from the
Skills Funding Agency to deliver education and training.
If you are responding on behalf of an organisation please make it clear how the views of members were assembled.
Responses to questions are welcome from all of the above
Question 1: Should Traineeships funding have a greater focus on positive outcomes than it does at present? (Paras 1-9)
X Yes No Not sure
Please explain your response:
As Traineeships are targeting those closest to the labour market, it’s crucial that this is not just a training programme but leads to a positive, sustained outcome for the individual, either employment or a return to education or training. Employers & providers should be seeing the outcome as the main objective for the individual.
Question 2: Is it important for successful Traineeship delivery to have greater

consistency in funding arrangements between the 16 to 18 and 19 to 24 age groups?
(Paras 1-9)
X Yes No Not sure
Please give further information to justify your answer:
Whether a direct grant holder or provider, the Traineeship programme needs to be consistent in addressing 16
– 24 skills issues and therefore it’s really important that the funding can be as simple as possible, linked to whatever contract is held. So for
Education Funding Agency (EFA) or Skills Funding Agency (SFA) holders, consistency across Traineeship delivery is vital.
Question 3 : Are Apprenticeships, other jobs and further learning the right progression outcomes to reward?
(Para 12)
X Yes No Not sure
If you answered ‘no’ or ‘not sure’, please explain your answer:
The individuals who are targeted are NEET so it’s vital that they are moved out of this situation as soon as possible after the Traineeship and are not stuck in a cycle of training and re-training. Apprenticeships should be the primary outcome but a job
(beyond a three-month fixed contract) should also be an aspiration and a worthy outcome. Education outcomes need careful consideration to ensure they are a significant progression for the individual.
Question 4: Are the principles we are applying to the definition of job outcomes the right ones? (Para 15)
X Yes No Not sure
If not, what alternative principles do you suggest?
Yes although some tighter definition around causality might be required where multiple interventions have taken place for an individual. In some cases, the effort required to move the individual to a successful outcome may be disproportionate to their prior learning or academic attainment. Further examples and analysis of this component would be required.
Question 5: Should the job outcome definition for Traineeships exclude employment under 16 hours per week? (Paras 16-17)
X Yes No Not sure
Please explain your response:
Whilst any employment outcome is a positive step, employment under 16 hours shouldn’t be considered a positive outcome. Without fully understanding the complex

benefits scenarios (current and Universal Credit) it’s difficult to be absolute in this answer. However, contracts under 16 hours are less likely to offer a sustained outcome and there could be an issue with commitment from the employer to the individual. It could also further compound the problems with zero-hour contracts.
Question 6: Should the job outcome definition include self-employment, provided that the individual has an income equivalent to at least 16 hours per week at NMW?
(Paras 16-17)
X Yes No Not sure
Please explain your response:
We should encourage potential entrepreneurs to start out on their own.
Question 7: How far do the above examples support the principles set out in paragraph 15? (Para 18)
Comment:
They support them fully.
Question 8: What do you consider to be the benefits and drawbacks of each approach? (Para 18)
Comment:
Example 1
Benefits: a short period of measurement allows timely measurement and is more likely to be performed more easily as the distance between the provider and learner is shorter.
Drawbacks: four weeks is not a sustained outcome for the individual and they would be at risk from short-term contract offers made simply to complete the programme and obtain funding.
Example 2
Benefits: demonstrates the sustained outcome well and ensures the outcome remains timely.
Drawbacks: will be harder to track and complications could occur if the individual changes employment within the 13 weeks.
Example 3
Benefits: allows a clearer view of where the outcome is failing, ie, is it initial progression or sustained outcome?

Drawbacks: much too complex to administer (and therefore costly) and harder to track outcomes. May be a better option for providers that are already set up to administer Youth Contracts.
If you have an alternative proposal, please provide details and the rationale.
Example 2 is our preference, with an understanding that the 13 weeks may be disrupted, because they move from one job to another, but we should be able to demonstrate how the individual has been provided with sustained employment.
Question 9 : In your experience what proportion of trainees would you expect to progress into each of a) an Apprenticeship; and b) sustainable employment? (Para
18)
Please give details:
Our current programme is running in advance of places being available on our apprenticeship programme so our figures are a little skewed at the moment however aspirationally a suggestion would be:

85% apprenticeship or job

15% further learning.
If targets are applied to the split between jobs and apprenticeships then this could drive inappropriate action, eg, forcing a young person to complete a Traineeship as a pre-cursor to an apprenticeship (even though they were ready for an apprenticeship).
And there is an argument that apprenticeship demand is not generated from preemployment programmes, so an apprenticeship may not be available to a successful trainee.
Question 10 : Do you agree that further learning should be defined using the same reference period as that for Apprenticeships and other jobs? (Paras 19-21)
X Yes No Not sure
Please explain your response:
Suitable further learning should be counted as progression. A further consultation should be undertaken as to what is deemed as sufficient progression.
Question 11: If not, what definition do you propose is used and why? (Paras 19-21)
Comment: N/A
Question 12: Should further learning as an outcome be restricted to particular types or levels? (Paras 19-21)
X Yes No Not sure

Comment:
As per question 10, a further consultation on what constitutes further learning should be undertaken. As a top level recommendation, the level should be higher than the academic attainment level held by the individual post Traineeship and be vocationally relevant to their development plan.
Question 13: Please provide details of what type of further learning after a
Traineeship should be considered an appropriate progression outcome and give reasons for your answer.(Para 19-21)
Comment:

Learning that advances the individual ’s academic attainment from their
Traineeship exit point.

Learning that is linked to the individual’s aspiration or vocational educational requirements.
Question 14: What proportion of trainees would you expect to progress into further learning? (Paras 19- 21)
Comment:
Fewer than 15%.
Question 15: How do you track learner outcomes currently and what do you use as evidence to validate outcomes? (Paras 22-23)
Comment:
Learners are tracked depending on what route they take.
Trainees we employ are tracked via our own payroll/HR system.
Trainees employed via our partner organisations, eg, Manpower are tracked on a monthly basis via feedback.
Trainees employed outside of our formal network or that go into further learning are contacted on an individual basis using email/text/call.
Question 16: How could we use matched data now and in the future to support our understanding of outcomes for trainees? (Para 24)
Comment:
Matched data either via HMRC or Job Centre Plus (JCP) would enable us to ‘look up’ an individual’s status. We would need to agree the look-up method or a batch submission (similar to how Learning Records System finds a unique learner number).

Question 17: Are these the correct principles for an outcomes-based Traineeship funding system? (Paras 25-26)
X Yes No Not sure
Please explain your response:
The last paragraph is perhaps the hardest to achieve consistency on; we also need to ensure that Traineeships are not being used for those who are still some distance from the labour market.
Question 18: Which of the four approaches do you believe would deliver the principles in paragraph 26 most successfully? (Paras 27-29)
1 2 x 3
Please explain your response: x 4
Both options 3 and 4 are suitable. It should be noted that this response is from an employer provider and we do not face some of the same issues as training providers, especially cash flow.
There should be a consideration made for an alternative method of performance monitoring so that the payments are made based on programme completion and the contract performance (percentage with sustainable outcomes) used as a method of checking quality.
Question 19: Are there alternative approaches that would better deliver the principles in paragraph 26? (Paras 27-29)
Yes No x Not Sure
Please justify your answer:
One issue being faced by providers, especially those that sub contract, is what percentage of funding is attributed to the single or milestone payment versus the final sustainability payment. With a low percentage ratio, the provision will be too risky for many providers to operate and with it being too high, there will not be the focus on the outcome. One solution may be to performance manage the contract rather than weight funding.
Question 20: Do we need additional mechanisms to prevent any abuse of the flexibilities in the programme, which could lead to insubstantial and insufficiently stretching programmes? If so, what do you suggest? (Paras 27-29)
Yes No x Not Sure
Comment:
Without knowing all the mechanisms in place it’s difficult to answer this. However,

focus needs to be on:
1. ensuring the assessment of an individual
’s suitability for a Traineeship is robust and fair
2. ensuring that outcomes are sufficiently rewarded.
Question 21: Do you have any comments on the proportion of the funding that should be paid at each stage of the programme?
(Paras 27-29)
Comment:
See previous comments about weightings. The balance needs to be found between giving providers sufficient payments to meet upfront costs and ensuring that outcomes are rewarded.
Question 22: Which option do you consider will make it most likely English and maths learning will be stretching?
Option 1 x Option 2
Please explain your response:
To ensure best value for funding and that English and maths can be given the focus and priority they need (in many cases this will specialised provision), the funding should be separated.
Question 23: Which option do you consider will make it most likely English and maths learning will be continued to completion after a traineeship has finished, and why? (Paras 30-35)
Option 1 x Option 2
Please explain your response:
By funding separately, learners
’ progress and movement to other learning providers will be easier to administer and the success and funding more transparent.
Question 24: Which option will be easier to administer for training providers, and why? (Paras 30-35)
Option 1 x Option 2
Please explain your response:
As an employer provider, separate funding would make it slightly easier to administer.

Question 25: Should the current arrangements for administering learning support funding to providers and financial support for learners continue to be applied to
Traineeships from 2015/16?
(Paras 36-37)
Yes No
Please explain your response: x Not Sure
We do not use the bursaries available and if disadvantage uplifts continue as they are (or the funding is reformed sufficiently) there wouldn’t be a reason to continue with the current funding past 2015/2016. Most learners are on short programmes so as long as the new funding can be in place (and explained) before March 2015 then this would allow time for new arrangements to be put in place.
Question 26: If not, what would you change as a means of bringing greater consistency to the way learners are supported across 16 to 24 Traineeships in order to best support disadvantaged learners? (Paras 36-37)
Comment: N/A
Question 27: Do you think that Traineeships funding should continue to be contracted through the existing arrangements, or aligned with the current
Apprenticeship arrangements?
(Paras 38-42)
Existing Arrangements x Apprenticeship Arrangements
Please explain your response:
As an employer provider without an EFA contract, we receive a translated payment into our SFA contract. This makes it easy for us to administer. Going forward, providers should have Traineeships aligned with their existing contracting so if EFA is the preferred method this should continue.
Question 28: Will the contracting route influence the position of traineeships alongside Study Programmes, Apprenticeships, or other programmes and if so how?
(Paras 38-42)
Yes x No Not Sure
Please explain your response:
This may be different for training providers. However, as an employer provider this will not make any difference to how we conduct our programmes.
Question 29: Should the eligibility rules for 19 to 24 year olds be changed so that 19 to 24 year olds can undertake a Traineeship if they are qualified to a Full Level 2?
(Paras 43-47)
X Yes No Not sure

Please justify your answer:
Many individuals are not eligible for Traineeships due to their prior attainment but they are clearly need help to progress into employment
Eligibility should be based on either/or and components of these criteria should include:

prior attainment. If full Level 2 needs to be applied then this should be on the condition that the full Level 2 contains GCSE maths AND
English at A
– C. There should also be an option to discount certain vocational qualifications based on their relevance or impact

period of unemployment. If the individual has a long period of unemployment, then this should allow the provider some flexibility on eligibility.
Question 30: Should this depend on the nature of the Level 2 qualification and if so how? (Paras 43-47)
X Yes No Not sure
Comment:
Yes, certain qualifications (vocationally irrelevant ones) should be discounted from general eligibility.
Question 31: Should this depend on whether a person already has already reached a high enough standard in English and maths? (Paras 43-47)
X Yes
Comment:
No Not sure
Yes. As in previous questions, if an individual has not attained a high enough standard in maths or English then they should be allowed onto the programme.
Question 32: If a change is made, do you consider that it is necessary to make the change in 2014/15 or 2015/16? (Para 43-47)
2014/15 x 2015/16
Please explain your response:
Not sure
Whilst a quicker change is desirable, in contract changes are very difficult to manage and it is unlikely in the current climate that the agency and their systems will work properly if this change is instigated in the current contract year.

Did you deliver Traineeships in 2013/14?
X Yes No
If yes, to what age groups?
X 16-18 x 19-23
Did you deliver Apprenticeships in 2013/14?
X Yes No
If yes, to what age groups?
X 16-18 x 19-23 x 24+
Do you plan to deliver Traineeships in 2014/15?
X Yes No
If yes, to what age groups?
X 16-18 x 19-24
Do you plan to deliver Apprenticeships in 2014/15?
X Yes No
If yes, to what age groups?
X 16-18 x 19-23 x 24+

Have you offered work experience placements to young people undertaking
Traineeships during 2013/14
X Yes No
Do you plan to offer work experience placement to young people undertaking
Traineeships during 2014/15
X Yes No
Do you have any other comments that might aid the consultation process as a whole?
Please use this space for any general comments that you may have, comments on the layout of this consultation would also be welcomed.
Thank you for taking the time to let us have your views. We do not intend to acknowledge receipt of individual responses unless you tick the box below.
Please acknowledge this reply x
At BIS we carry out our research on many different topics and consultations. As your views are valuable to us, would it be okay if we were to contact you again from time to time either for research or to send through consultation documents?
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BIS/14/856RF - Traineeships Funding in England - Funding Reform Technical Consultation - Response Form