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The Guardian in
its recent editorial LINK on the Government's
newly introduced Apprentice Levy stated:
The
biggest flaw is that, like so many other government initiatives, this latest
attempt to boost the number of apprenticeships could have been designed to be
gamed. Experience has surely shown by now that setting a target, generating the
cash, and launching the scheme before systems of monitoring and assessment are
up and running is an open invitation for employers to cheat.
I
can reveal that a KMPG report into the College fraud has exposed serious
deficiencies in the so called tightened monitoring system LINK in place,
and in my view, provided sufficient evidence backing up the Guardian Opinion of
17 April April 2017
The KPMG report
which focused on the apprenticeship training provided (or rather, it appears,
not provided) by Keyrail LINK was limited in scope and provided 'for
information purposes only', however, beneath the bland account's language, KPMG reveal
some pretty devastating deficiencies:
• Despite assurances
that due diligence had been performed and a contract given
to Keyrail Training Solutions for signing KPMG had
been unable to find the majority of due diligence paper work or a signed
contract
• An increase in
approved apprentice numbers from 20 to 90 was not underpinned by
documentation or risk assessment
• Learner evidence was
requested from Keyrail but was delayed or not completed meaning the
the College failed to comply with Skills Funding Agency's funding rules
regarding ongoing monitoring
• The College did not
have a formal policy regarding monitoring of subcontractors prior to July 2015.
• Out of a total of
learner 40 files reviewed KPMG considered all were ineligible for
funding as there were multiple compliance issues, including no achievement
evidence
• Of the 79
apprentices for whom funding was claimed, only 7 were recognised by the
employer with whom they were supposed to be placed, Specialised Engineering
Services Limited (SES)
KPMG summarise
by stating they did not see sufficient evidence to demonstrate that valid
learning took place in relation to the Keyrail apprentices
The
Report went on to observe the following risks:
The College’s current subcontractor procedures are insufficient to demonstrate
compliance with the SFA overall subcontracting requirements.
The College is unable to demonstrate compliance with the SFA overall subcontracting requirements.
The College is unable to demonstrate it complies with the SFA Selection and Procurement and Entering into a subcontract rules and requirements
The
College has reduced assurance over the completeness and accuracy of enrolment
documentation relating to subcontracted provision. This increases the potential
for errors within the subcontracted population on the ILR not being identified.
In turn, this could detrimentally affect the College’s funding claim should
enrolment issues be identified by any external audit of the College’s ILR
The
College is unable to demonstrate sufficient controls over the monitoring of
apprenticeship subcontracted provision. The inability to determine the level of
outstanding review/contact evidence for all apprenticeship subcontracted
learners increases the risk of ‘gaps’ in a learners on-programme activity and
therefore the risk of an incomplete and inaccurate ILR, resulting in a
misstatement of the College’s funding claim. This will directly impact on the
College’s decision making process over the determination of monthly payments to
its subcontractors.
If a
learner is not registered or incorrect registered, then the College is at risk
of not being able to substantiate a learner achievement. This will impact on
any achievement funding claimed, as well as success rates.
The
College is unable to demonstrate it complies with the SFA Monitoring of
Subcontractors rules and requirements, and has increased risk of data
completeness and accuracy issues relating to subcontracted provision
The College is unable to demonstrate it complies with the SFA Fees and Charges rules and requirements
The
College is unable to demonstrate it complies with the SFA Monitoring of
Subcontractors rules and requirements.
In
addition, as KMPG only had available documentation going back to March 2015, it
made further comments as to the implication of what it found having looked at
the available documentation. However, because of the lack of documentation it was
unable make recommendations:
During the course of the substantive testing, a number of observations have been identified which are recorded below. No recommendations are made to the College as Keyrail ceased trading in May 2016. The documentation retained by the College in relation to Keyrail is considered as final as there is no scope for additional evidence to be provided.
1. Where learners are
enrolled onto apprenticeship programmes that do not meet the funding eligible
rules and criteria, all funding claimed is deemed ineligible
2. There is a risk that
funding claimed and/or data held in the ILR cannot be substantiated to
underlying records
3.
There is a risk that where no underlying records are retained, funding claimed
is deemed ineligible
4.
Where underlying records are incomplete or potentially contradictory, there is
a risk that the learners English and maths enrolments on the ILR
cannot be substantiated
5.
There is a risk that the funding claimed is not supported by documentation
signed by the learner.
6.
There is a risk that the funding claimed is not supported by underlying records
CNWL made total payments to Keyrail for what
appears to be non existent apprenticeship training of £214,572. The College
discovered in early summer 2016 that the company had been dissolved.
One
learner in a College telephone interview in April 2016 put it succinctly:
The course no longer going on and this was all a scam. The staff
forced to go in and do the course; if not they were sacked (sic).
In
a further twist, highlighting the growing concern over apprenticeship, UCU at
its annual congress adopted a resolution calling for an apprenticeship charter LINK
The TES quoted Peter Monaghan, regional secretary of the UCU
Eastern and Home Counties Committee:
Certainly I would support the fact that apprenticeships
shouldn’t be at the expense of a wider, broader curriculum, most
definitely...and also I would say the key to the success of apprenticeships in
the future is our involvement, not employers’ involvement, our involvement as
unionists and educators.
In
my view, the UCU Congress motion on Apprentice charter as well as Guardian
leader comment, lends strong support to the UCU branch at the College who are calling
for an independent public enquiry into the admitted subcontractor fraud LINK
Backing
the unanimous decision of his branch members for an independent inquiry, Indro
Sen, suspended Branch Secretary at CNWL, said.
When students are 10 minutes late, managers instruct the class
teachers to monitor their attendance. When teachers do not cross the "t)
and dot the"i" in their marked work, they are monitored by
their managers and some end up under capability procedures, but when a fraud as
large as £356K can take place under the very nose of SFA auditors, borough
police chief, Governors and senior management teams, who monitors their
performance?
Only an independent public enquiry can get to the bottom of this.
Can any students' life chances be said to be in safe hands unless each and
every sub-contractor is thoroughly checked out on the Government declared Sub
contractor list and those checks are made public for students to see what they
are getting into. Until such time, Mr. Boles should consider putting the levy
scheme into abeyance.
It
is not known how SFA and the college have reacted to this call for
an independent public inquiry, however, it is clear the KMPG report itself is not such
an inquiry. It is to be hoped that CWC undertook due diligence prior to
the merger decision.
Greening
would be wise to delve a little deeper into the merger between College of
North West London and City of Westminster, before rubber stamping
it. LINK
If she did so, she would only be carrying out her boss, May's manifesto promise of
greater scrutiny over mergers, a bit earlier and proactively. This related to commercial mergers but should also apply to corporations as they move closer to commercial models.
