Developing a Centre based model for Ofqual regulated EpAOs

Recognising that working together and combining efforts produce stronger results than individual working, Jacqui Molkenthin from JEML Consulting, Sarah Sutcliffe and Jackie Stark from ProAssess have pulled their heads and EpAO/AO expertise together to develop a range of articles and resources for EpAOs to help them understand the rapid and fundamental changes to EPA and what it means for governance, resources, policies, strategies, and operation. This is the first of a series of articles designed to support the sector.

Although a lot of the detail of the new assessment plans are yet to be confirmed, there are a few things we can be fairly confident in, one of which is a move towards a Centre based model of EPA delivery. EpAOs that are already AOs for other qualifications will be aware of, and operating, Centre based models of delivery, but for the majority of EpAOs where they have only ever been recognised by Ofqual to deliver EPA, Centres are a new concept which requires a change of approach.  Whilst we do not know how many standards will move to this model, or the timescale around it, there are things that Ofqual regulated EpAOs can do to prepare themselves. This article provides an introductory overview to support the preparation.

What is a Centre?

In accordance with the Ofqual EPA level guidance a Centre is any organisation that delivers part of a qualification on behalf of an awarding organisation. For example, a Centre will deliver an assessment where no person employed or contracted by the awarding organisation is present while the assessment is being taken.  In an EPA context, an employer or training provider that delivers or marks an assessment or part of an assessment will meet the definition of a Centre, including where they provide invigilation.  Where this applies, the awarding organisation must comply with Ofqual Condition C2.

What will you need to consider when planning and developing your approach?

1. What elements of the EPA will be undertaken by a Centre and when – this will be a bit of guess work at the moment because the assessment plans have not been re-written, but you will be able to model scenarios for the delivery EPA across each type of assessment.
   
2. The role of the Centre(s) – Will the Centre be administering, invigilating, or marking / grading the assessment? The role of the Centre will determine your approach to Centre approval and the application of your CASS.
   
3. Your Centre application and approval process, including any charges you will make for undertaking the approval process  – You must ensure that you only work with Centres that have the capacity and capability to comply with your requirements and therefore your ability to continue to meet the Ofqual conditions of recognition. This means that you will need a process / benchmarks in place to assure yourselves that the Centre:
   – has appropriate staffing in place (volumes, skills, and qualifications), including internal quality assurers;
   – has appropriate systems in place, including how those systems integrate with yours;
   – has appropriate resources in place (you may wish to carry out credit checks to confirm this);
   – has appropriate facilities and equipment to undertake their role; has appropriate policies in place, such as data protection and security of assessment materials, complaints, appeals, conflict of interest, incident management, health and safety, malpractice/maladministration, reasonable adjustments and special considerations, safeguarding and whistleblowing. Please note that the use of Centres will mean that the AO/EpAO will need to update its own policies to cater for AO/EpAO direct delivery of EPA as well as Centre delivery of EPA.
   
   Once the approval process is complete the AO will have evaluated the level of risk of that Centre in delivering the assessment, this risk level will determine the level of controls that are used as part of the CASS strategy.
   
4. Centre Agreements – Under Condition C2 there are a number of obligations placed on the Centre though a written enforceable agreement between the AO and Centre which requires the Centre:
   – to have a workforce of appropriate size and competence alongside management and resources to undertake the delivery of the qualification as required by the AO,
   – to comply with equalities law,
   – to hold and operate a complaint handling procedure and appeals process,
   – to comply with requests for information or documents made by the AO, and to assist the AO in carrying out monitoring activities.
   
   The agreement must also set out the compliance requirements  for the Centre when involved in delivery,  a sanctions policy to be applied in the event that the Centre fails to comply with these requirements, and a process to follow in the event of withdrawal (whether voluntary or not).
   
   The application of Condition C2 also brings into play all Ofqual conditions as the Centre must take all reasonable steps to ensure that the AO is able to comply with its Conditions of Recognition. But in particular condition H will become critical – the Centre Assessment Standards Scrutiny Strategy, which includes moderation. This is often referred to as the CASSS
   
5. The CASS – Where an assessment is marked by a Centre the AO must have a Centre Assessment Standards Scrutiny Strategy (Ofqual Condition H).  The strategy will details the controls the AO has in place to provide assurance of ongoing compliance with the Ofqual Conditions and therefore regulatory compliance. Such controls may include the moderation of results prior to being issued, and will definitely include monitoring and external quality assurance. Ofqual has a great guidance resource on developing CASS strategies which can be accessed here with additional guidance in relation to moderation here.  Don’t forget that the use of the word moderation in the current assessment plans often has a different meaning to the use of the word moderation by Ofqual.
   
6. Your approach to EQA – this is part of the CASS, but I wanted to draw it out as it willbe new to AOs that solely deliver EPA as they currently provide internal quality assurance as they are the deliverer of the EPA.  Under a Centre model the Centre will be delivering the assessment and as such the AO moves to a position of EQA provider – externally quality assuring the work of the Centre.
   
7. Guidance and training – As an AO you will be required to develop and provide guidance (and potentially training) for your Centres.

Another area that we will start to see emerge is the requirement for EpAOs/AOs to have an assessment strategy. The reason for this is the removal of many of the assessment details from the assessment plan, as can be seen in the foundation apprenticeships. An assessment strategy provides the assurance for Ofqual that the AO can develop fit for purpose assessment, and we will be writing a separate article around the development of an assessment strategy.

By Jacqui Molkenthin from JEML Consulting, Sarah Sutcliffe and Jackie Stark from ProAssess