Level 3 apprenticeship consultation is ‘flawed’

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The consultation on a new apprenticeship standard is ‘deeply flawed’ and ‘bordering on a joke’, sector leaders have said.


Level 3 Early Years Educator apprentices will be required to hold an ICT qualification

The one-page consultation, which ends on Wednesday (17 May), is seeking employers’ views on what should be included in the new Level 3 Early Years Educator apprenticeship standard.

It is the first major output from the trailblazer group, led by nursery chain Busy Bees, which took over after the original group was sacked in February.

penny-tassoniEarly years consultant Penny Tassoni called it a ‘huge disappointment – bordering on a joke’. She said, ‘There is no requirement to identify oneself, put an email address or even a job role. There are five questions – simple at best and nowhere to put a comment or a suggestion. I don’t know how this can be seen as a proper consultation. It is also possible to fill it in several times, so could be open to manipulation.’

She also did not think it qualified as a formal consultation because there ‘isn’t the opportunity to improve the standard and act as a critical friend’.

‘Nowhere in the standard’s opening “role profile” does it talk about the need for [practitioners to have] effective communication with children,’ Ms Tassoni said.

She added it was not possible to suggest including this need because there was no comment box. However, the group has since added a comment section.

‘If it isn’t in the qualification, no teaching time will be available for it. Everyone in the sector needs to [get involved] as it will make for a better qualification and better practice. Once a qualification has been set up, it is very difficult to unpick it,’ Ms Tassoni said.

ross-midgley-newRoss Midgley, director of training company PBD, who was on the original trailblazer group and co-wrote the original Level 3 standard, said the consultation was ‘deeply flawed’.

‘It is being presented as if it were a root and branch reform,’ he said. ‘The standard itself is impossible to disagree with. If it is to equip people to practise as EYEs, it must include an EYE qualification and a Paediatric First Aid certificate as a minimum. Merely repeating the Government’s criteria for an EYE under the heading of “attributes and behaviours” adds nothing.

‘The only important questions in this consultation relate to things that we haven’t yet seen – the ICT qualification and the assessment plans.’


Both Busy Bees' and the original trailblazer group’s standards are largely based on the required elements of the Early Years Educator (EYE) qualification. Elements such as ICT and literacy and numeracy qualifications are extra. The assessment plan is also a separate document, and relates to how the new ‘end-point assessment’, introduced as part of the Government’s reform of the apprenticeship system, will be carried out.

The survey asks respondents to rate out of four their agreement to five statements. The question on ICT reads, ‘The completion of an ICT in the Early Years certificate should be a mandatory component of the EYE apprenticeship standard. The qualification will focus on providing practitioners with the knowledge on how to use ICT effectively within a childcare setting.’

The current ICT options include a functional skills Level 2, which employers have criticised for requiring irrelevant skills such as spreadsheet management.

suzi-graySuzi Gray, early years technical adviser at awarding body City & Guilds, said there was confusion about which ICT qualification would be necessary.

‘It is interesting that [it] identifies the need for apprentices to “be able to facilitate good practice in the use of ICT in early years”,’ she said. ‘On-programme “qualifications” include reference to both ICT functional skills and an Award in ICT in the Early Years. Does this mean that the apprentice will need to attain both of these or will they and/or their employer be able to choose which is most appropriate?’

She added, ‘The finer detail, which we expect to see in the assessment plan, will help guide employers, providers and awarding organisations as to how best to prepare for delivering this qualification successfully.’

Mr Midgley said, ‘If EYE apprentices must have an EYE and a PFA certificate anyway, what is left for the end-point assessment to assess? My fear is that, armed with the results of this consultation, the group will go on to devise a complex and time-consuming assessment process just to have something to show.

‘We need a complicated, expensive full-day end-point assessment like we need a hole in the head.’

Busy Bees told Nursery World a separate consultation was planned on the end-point assessment, 'within the next month'.


Apart from Busy Bees, the trailblazer group features small nurseries and Birmingham City University, with the National Day Nurseries Association playing an advisory role and disseminating the consultation. Bright Horizons is not a member but is ‘working closely’ with the group.

The former trailblazer group, which was formed in March 2014 and stood down after a row about GCSE equivalents led to a delay in publishing the standards, had members including the Pre-School Learning Alliance, NDNA and chains Kids Allowed, Tops Day Nurseries and Bertram. Busy Bees and Bright Horizons left the group in August 2014.

fay-gibbinFay Gibbin, training manager at the Busy Bees Training Academy, said the group was ‘working alongside a number of trusted employers and organisations’ to review the former trailblazer’s draft apprenticeship standards.

She added last Monday that the survey had garnered 160 responses. ‘Anonymity for those completing the survey is important as it is acknowledged that this improves both the quality and quantity of responses,’ Busy Bees said a press statement.

Ms Gibbin said, ‘While the vast majority of responses to date have been constructive, we are aware of concerns raised by a few individuals. The standards within the apprenticeship Level 3 qualification are already set and cannot be changed, and this has influenced the nature of the question. Those concerns that have been raised are being treated seriously and will be considered as part of the feedback process.

‘There will be further consultations held to develop the frameworks for the Level 5 and 6 EYE apprenticeship standards, [for] which there will be much more opportunity and scope to provide feedback as the standards for these are not already defined.’

The Level 3 consultation calls on employers to take part, stating, ‘It’s absolutely crucial that the sector takes part… to help raise the profile of an Early Years Educator (EYE) and ensure that the apprenticeship standards include what employers are looking for.’

The draft standard also contains a new requirement for a Level 2 food hygiene certificate.

Busy Bees said the consultation results will be made public.


The draft Level 3 standard contains this specified qualifications list:

  • Apprentices must successfully complete a Level 3 Early Years Educator qualification.
  • Apprentices without a recognised maths, English or ICT qualification at level 2, including functional skills, will be required to achieve this prior to taking their end-point assessment.
  • Level 2 Food hygiene certificate.
  • Full 12 hour Paediatric First Aid certificate.
  • Award in ICT in the Early Years.

For more from Suzi Gray, see More answers needed

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