Since April 2017 those public sector bodies in England with 250 or more employees, including schools and multi-academy trusts, have been legally required to appropriately demonstrate how they have met, or attempted to meet, the public sector apprenticeship target. Therefore, employing an average of at least 2.3% of their headcount as new apprentices starts, up to 31 March 2021. The target is aggregated over four years, so it is not a requirement to meet the target each year. If your school is in scope, you must annually publish and report to the Department for Education on your progress.
The Apprenticeships (Miscellaneous Provisions) Regulations 2017 came into force on 31 March 2018 and brought into effect the public sector apprenticeship target. To accompany the regulations, the Department for Education has statutory guidance, but there can be a lot to get to grips with.
These FAQs will introduce your legal requirements:
1) How do I know if I am responsible for Apprenticeship Reporting?
Two factors determine if you are in scope of the public sector apprenticeship target, meaning that you are legally responsible for apprenticeship reporting:
- the type of school you are
- who employs your school’s employees
If you are a Maintained school, where the Governing Body is the employer, such as a Foundation or Voluntary-Aided school, and you employ more than 250 employees in England, then the Governing Body is responsible for reporting on progress towards meeting the public sector apprenticeship target for all the schools it maintains.
For Maintained schools who employ more than 250 individuals in England, and where the employer is the Local Authority, the Local Authority is in scope and responsible for reporting on progress towards meeting the target. Your school will be expected to be included within the Local Authority target. Therefore, you should speak to your Local Authority about how to contribute towards the target. Local Authorities are also permitted to set out progress in their schools separately in their annual return.
If your school is part of an academy trust or multi-academy trust that employs 250 or more people in England, the trust is in scope. Academy trusts came into scope from 31 March 2018.
2) What if the target hasn't been met?
You may have had regard to the public sector apprenticeship target but still be failing to meet it. In this case, you should use the Apprenticeship Activity Return to explain how you have sought regard to the target, as well as outlining any factors that you feel may have hindered your efforts to meet it.
In addition to quantitative and qualitative elements, explanations should provide sufficient detail to evidence your school’s actions. You should provide evidence which identifies where you have actively considered apprenticeships, either for new recruits or as part of the career development for your existing employees. In addition, you should identify where you have encountered and attempted to overcome challenges in employing apprentices.
It may also be the case that you have not met the target, but can highlight mitigating factors which demonstrates your commitment to apprenticeships. For example, you might employ a higher proportion of apprentices on two or more year apprenticeship programmes, or you might be planning a major recruitment drive the following year which would bring the average number of apprenticeship starts up to or beyond the target.
3) What counts as an apprenticeship for reporting purposes, are apprentices just young people and new recruits?
Within schools, apprenticeships cover several roles and a range of education levels, from level two, equivalent to five GCSE passes at Grades A* to C, or 9-4, all the way up to level 6 and 7, which are equivalent to a Bachelor’s or Master’s degree.
Contrary to common stereotypes, apprenticeships are not just for young people and new recruits. It also does not matter whether they are already employed in your school or not. The core rules governing what an apprenticeship is state that apprentices must:
- be employed in a real job and working towards achieving an approved apprenticeship (you can search approved apprenticeships on the ‘find apprenticeship training for your apprentice’ page of gov.uk)
- receive apprenticeship training that lasts at least 12 months
- spend at least 20% of their time on off-the-job training, e.g. mentoring, coaching or completing formal training or qualifications
- be paid at least the relevant national minimum wage (though most will be paid more)
4) How do I submit my report?
Most bodies will send their Data Publication and Apprenticeship Activity Return to the Department for Education, through their Apprenticeship Service account. If you are a levy paying organisation, you should make sure that you are registered on the Apprenticeship Service to submit your annual return.
You will need the following information to complete the report:
- the number of employees whose employment in England began during the reporting period
- the number of employees who began an apprenticeship in the period (both new apprentice hires and current employees who started an apprenticeship)
- the number of employees employed in England at the end of the period
- the number of apprentices working at the end of the period
- the number of employees immediately before the start of the reporting period
If in the first reporting period, you must also provide:
- the number of apprentices working immediately before the period
For EPM customers, you will find your Employee Information Report or MAT Employee Information Report (as appropriate), on the EPM portal under ‘Downloadable Reports’. This will assist you in completing your report. If you are a non-levy paying organisation, the form and details of where to send your report can be obtained by contacting the National Apprenticeship Service Support Service.
The National Apprenticeship Service Support Service can be contacted on 0800 015 0600 (option 1 then option 2) or email firstname.lastname@example.org.