Rubitek Talks - Demystifying Apprenticeships Episode 2 - What makes a great apprenticeship provider?
Welcome to Rubitek Talks, brought to you by Rubitek Solutions with me, Kerry Linley.
This podcast blows the doors open on apprenticeships. It aims to busy myths like 'apprenticeships are just for young people' or 'you can't got to university if you do an apprenticeship' as I interview a range of guests who tell their own apprenticeship stories.
Kerry Linley: Welcome to the second podcast in our 'Demystifying Apprenticeships' series. The window has recently opened for new applications to the Register of Apprenticeship Training Providers (or ROTAP as it is sometimes referred to) and we through it would be helpful, timely and topical to talk about what makes a great apprenticeship training provider, and what any provider thinking about applying to the register should consider. I am delighted to welcome a very special guest today - he is in his own words a seasoned campaigner for apprenticeships, often called in to bring about a change in strategy by providers who have had a less than satisfactory Ofsted grade, he is a governor, a non-exec director and currently an assistant principal for an adult community college, Paul Butler. Paul it's a pleasure to have you on the show.
Paul Butler: Hi, Kerry, how are you?
Kerry Linley: I'm really good thank you Paul. I'm looking forward to this chat. I think we've got some really interesting points to make and things to talk about.
Paul Butler: Yeah, absolutely. Yeah.
Kerry Linley: How are you feeling? Have you done a podcast before?
Paul Butler: I've done radio interviews previously and I swore in a radio interview, so I'm frantically trying and restraining myself to ensure that all my language is suitably clean for this podcast.
Kerry Linley: No problem. I'm sure that it will just spice things up if you do, but I will try my hardest not to make you swear.
Paul Butler: No problem.
Kerry Linley: Paul, it's an interesting topic we've got this morning and you and I spoke previously about the three different stages that any apprenticeship training providers should think about very carefully, and I'd like to focus on these during our conversation today.
Paul Butler: Yeah, sounds good. I think the thing is that people have got to realise, and it's interesting given the new criteria that are out, it also applies to existing providers as well. And the thing is, it's not just about the application. An application is a process to get you on there, but there are certain things you need to do and understand before, during and after, that are absolutely critical and without that, the whole thing falls apart. If you're a private business, then chances are you lose your contract, etc and possibly lose your business, you know, and on the really important side is there are young people and adults, there who get you know, a pretty darn bad deal out of it, bad experience, so they lose the chance to progress, in a, in a job in a career and it also taints people's view of apprenticeships as well, as a brand and that I think is probably the biggest scandal of what's going on. It's hard enough getting the word out there with, with the general public anyway, and I think that's largely being addressed, not through the government I must stress. That’s through providers and a load of really good people out there, you know, championing the cause. I've yet to see any real money being spent on actually advertising apprenticeships by central government since probably 2009, something like that. Yes, you see the odd campaign but to see something that really gets out there and gives a really clear message I haven't seen something for many, many years, and bearing in mind where I came from, you know, many, many years ago at the national apprenticeship service - money was being spent, then with all the changes etc less money is being spent on actually marketing it to the right people. And what troubles me is this scenario where there's been so many reforms in the sector, you know, going over to levy and all the different reforms in terms of the structure of apprenticeships with standards, etc, etc, and the amount of incentives that are being put in place quite rightly to, to try and boost apprenticeships as a decent alternative. But, employers, particularly and carers and young people and prospective apprentices - all these people – there is initiative overload. So where is there a clear message? And that’s what troubles me. So being a good provider is not just about getting through RoATP, it's being able to convey out there to young people, prospective apprentices and an employer, A) what an apprenticeship is and B) what it does for you. And you don't see that necessarily in a RoATP application, but to succeed, you need to be able to understand what an apprenticeship is.
Kerry Linley: It's a really good point you make. So there have been so many reforms over recent years, but the marketing around apprenticeships and the messaging around apprenticeships, to the target audiences, so the people who should be considering apprenticeships, isn't necessarily the right message or it's not filtering through. I think there, there are a couple of things going on here and yesterday I saw a really interesting announcement, from the government's press office, and I'm not sure if they do this every year, but they are looking into the effectiveness of National Apprenticeship Week in 2021. So some kind of review of how effective National Apprenticeship Week was. So we may well see some things come out of that, that influence marketing messaging as we go forward.
Paul Butler: Yeah, absolutely. I mean, from what I saw, the last one and bearing in mind, the last one was during the pandemic, there was some fantastic stuff being done, but that is in spite of messaging that comes out centrally. That's providers and other organisations doing some really innovative stuff, really good stuff, their heart's in the right place, brilliant and employers as well, you know, so a lot can be done. But there needs to be some really clear messaging coming centrally because it can be very confusing if you're an employer, or someone that's looking to become an apprentice, or if you're a parent trying to advise your son, daughter, who's looking to leave school. Are they going to go on to Sixth Form? Are they going to go onto an apprenticeship or are they going to leave Sixth Form? Are they going to Uni, all these things, and the messages need to be clear. And part of that is the providers, and largely most of them are doing a fine job anyway, going out there and selling the offer in the right way to the right clientele. And that is going back to originally what I was saying, you know, in terms of becoming a good provider, you find the ones that are good and the ones that do well, actually have a clear idea of what an apprenticeship is and how it should be delivered.
Kerry Linley: So going back to the topic at hand then, so what makes an excellent provider. If we look at the three different stages: stage one, we'll call that before delivery. So a new apprenticeship training provider really needs to think about how it plans, and I'm underlining the word plans here to deliver excellence. Can you tell us what this means in practice and what impact that has got to have, not just on the RoATP application process, but on the training provider, as it starts to set up its business to get ready to deliver.
Paul Butler: Yeah. I mean, there's loads isn't there. Prior to, if you think of the RoATP application it’s there in the guidance, but actually it's understanding what it all means. So what is an apprenticeship? Well, it's not just a program that you can take off the shelf and deliver like in the old days, because you had your nice portfolio’s and dah-dah-dah, and you know, that's what an apprenticeship was with an NVQ etc, etc. Now you've got two sides of A4 standard that has to be delivered in conjunction and agreed with the employer. So understanding what that means now, and there's gotta be a lot more teaching and learning. So, if you're doing an application, understanding what an apprenticeship is nowadays is absolutely critical and that goes through post-application. So one is, understanding what is an apprenticeship and what goes with it. There are many successful commercial providers that suddenly think, you know, and quite rightly think, but we do a lot of work with employers. Perhaps we should get some funding for this and develop an existing management program. Let's say for instance, they do some CMI commercially or ILM type management programs. How can we make this, can we capitalise on this opportunity by drawing down from the levy and that's a logical thought process and think right we can go for that. But all of a sudden they'll be delivering a program in a totally different way, and all of a sudden they have to go down the route of things like knowledge, skills, and behaviours, rather than the knowledge type program that they might've previously delivered, you know, knowledge and principles, that type of thing. So understanding what an apprenticeship is and what it entails. What is different about an apprenticeship compared to other training programs that are delivered? That's a key thing, because again, you might be already drawing down public funding for other programs, so things like AEB through a subcontract or ESF and all these wonderful funding streams. But they think right, I'll go for RoATP. So, okay, well I've drawn down public funding before - I know that there are certain hoops we’ll need to jump through, but never delivered an apprenticeship before. So understanding what the differences are between other funded programs as well. So that's one. Policies and procedures. Now, you know Kerry, we’ve both done RoATP, we've worked with providers before on RoATP and you know the previous incarnation, policies and procedures need to be there. Great. But actually understanding what those policies and procedures are and how they relate to an apprenticeship, not just having a Safeguarding - how does it reflect on the provision you're delivering, particularly in the sectors you're delivering because a safeguarding policy for a training provider delivering construction is vastly different for one that's delivering IT and Business Admin, and it should reflect that.
Kerry Linley: I'm sure you get asked, as I have been asked “do you have any standard policies that we can just copy from” as part of their application.
Paul Butler: Yeah. All the time. And my answer is no.
Kerry Linley: Go and write it yourself.
Paul Butler: I can give you some bullet points and pointers in terms of what you need for content, but they need to apply to what you're actually delivering and the clientele you're delivering to otherwise it's meaningless. And if it's meaningless, then 1) it will fail; 2) it will fail at Ofsted and if you fail at Ofsted on safeguarding you get bombed out anyway; and 3) you're doing, and most importantly, you're doing a major disservice to your learners and employers and it could be dangerous, you know, make no bones about it. So, it's understanding then that the policies and procedures, there's no off the shelf thing. And if a provider is offered an off the shelf solution, then perhaps they need to be asking some sticky questions of the person they're working with, if that's the case. Or if they've already got policies and procedures in place, they need to review them. For the reasons I've just articulated, this is really important. They need to refer to apprenticeships specifically because 9 times out of 10 they're delivered in the workplace anyway. So therefore, you've got all the health and safety issues, etc, etc. But it's the whole package and also don't forget now we're delivering online as well. So how does that reflect, you know, you're thinking about, so around safeguarding - a lot of the safeguarding could be around Cyber Security and Cyber Bullying etc. So – a whole different world.
Kerry Linley: So, I was just about to ask you under the new guidance, has much changed taking into account the last 12 months that we've just had and the change in delivery, it's moved vastly to online. So, has the application to RoATP guidance changed to take that into account?
Paul Butler: I don't think it's changed massively. The agency, essentially what they want is a nice, warm feeling that they are going to be investing their money in something that is going to give a decent experience to learners and employers that is safe and it's value for money.
Kerry Linley: The agency being the ESFA, the Education Skills Funding Agency.
Paul Butler: So those guys, they are the custodians of the register so I don't see an awful lot in terms of implicit, but when you're actually articulating it and answering some of those questions, yeah, you need to. So, for instance, if we look at safeguarding, etc, there needs to be, and also the business continuity planning, because those are two key elements of the submission and their documents, you need to upload. So, business continuity plan, if you haven't gotten anything in there that reflects on a pandemic, because, you know, sure as eggs are eggs, this, this thing's going to be around for a while. And we may be in for further lockdowns, regardless of what people are telling us. We’ve already had three, depending on where you are you might have even had more so, and chances are with other variants going round and you know, all this wonderful stuff that's going on in terms of vaccines you can't write-off other effects such as the lockdowns, etc. So therefore, your business continuity planning must reflect that.
Kerry Linley: So, knowing what your backup plans are; having those in place. So, we've talked about understanding the difference between commercial training and apprenticeships. We've talked about making sure your policies and your procedures, they work for apprenticeships, they're fit for purpose, they support your delivery. Is there anything else the provider needs to consider the before delivery stage?
Paul Butler: Yeah, I mean one critical one and there's been a lot, you know, on LinkedIn and various other forum, Promote-Ed and places like that, around financials, and quite rightly so. When you're opening yourself up to this new world, do your financials stack up to the ESFA's financial health check? And the scrutiny it's going to go under? And you need to make sure of that. So this is not something to take lightly and, make sure you've got proper accountants and whatnot and you’re up to date with all your financial stuff. I'm no, accountant, I don't profess to be and whenever I talk to providers, I only advise that they go and speak to financial professionals, and if necessary, have a chat with the ESFA as well. I don't go down that route and it worries me that there are consultants out there supporting providers that try to support that element, but don't necessarily know what they're doing. It's really important that if you don't know, you make sure you signpost them and just say hands up, I don't deal with that because that element, you can get bombed bombed out straight away. But also understanding the financial side in terms of how apprenticeships are paid for, an understanding that side of it as well because providers have gone bust. It's not a cash cow and people would be mistaken to think that.
Kerry Linley: Okay, and that's a really interesting point because we know from providers who have submitted their ILR claims, if they don't get that claim in on time, they don't get the funding for that month. So, when you talk about the financials, it's about being robust enough that you can cope with something going wrong in that process. You need to be able to pay the wages of your tutors and your staff and your delivery team, so that you're not going to negatively impact apprentices on programs and their employers and your own staff, if something goes wrong in that process. So, making sure that financially you are robust, but also having the right advice and expertise as part of your advisory team when you're looking at making this application process, and don't just accept the advice from someone who is not qualified to give it.
Paul Butler: Absolutely. That's critical. And then on the back of that, the other thing to bear in mind is around compliance. So therefore, if you're drawing down public funding and you haven't got the systems in place to evidence that you've completed that learning, there's nothing worse than being paid for something and then having it clawed back a few months later – and think of the impacts there on your financials as well. So, it's not just in terms of financial housekeeping prior and making sure you pass the health check, etc. It's also understanding the consequences of if you haven't got your systems and processes in place, particularly around audit and compliance and making sure you've evidenced the learning in an appropriate way. So you stand, stand up to scrutiny in terms of funding agencies, but then you also need to be able to stand up to scrutiny from the likes of Ofsted, who come in and if you get inadequate grades or insufficient progress, etc, you lose your starts first of all and then you could lose your contract. So you've got a scenario there. Actually understanding mechanisms in place that underpin quality and compliance, and it can't be just a tick box exercise it's actually understanding what they mean and more importantly, across the team, understanding what the consequences are if those systems fail. So understanding why.
Kerry Linley: So, if we just think about that - a working example of that would be, let's pretend I'm a training provider, I've submitted my ILR and I've got a bunch of learners on the ILR and I've said that their last date in training was, I don't know, the 1st of May 2021. If I can't evidence that that was their last date in training or their last date of engagement with me as a training provider and I am paid funding up to that period, I get an audit, I can't evidence that there was anything taking place up to that date. What you're saying is I could have that funding withdrawn because I can't evidence that training happened up to and including that date, is that right?
Paul Butler: Yeah, absolutely. I mean, let's face it the funding agency are the custodians of our taxes in this case, and you see all the time people complaining about MP's expenses, etc, etc. But misuse of funds is just as bad, isn't it? It's still wasting our taxes. So, if you can't provide evidence of the learning taking place and if you haven't got evidence, why not? And if the learning hasn't taken place, you're doing a disservice to a learner anyway, surely. So, it's wrong from every angle. That's why it's important that systems and processes are in place across the board, but more importantly, is that the team understand why.
Kerry Linley: I think some providers will put their hands up to this. So, they may not necessarily be unable to evidence that training has taken place, but that evidence is in lots of different locations. So, there might be communication over email, there might be stuff taking place in a classroom with a signing-in sheet with a tutor that hasn’t been in the business for a number of months, records can be quite disjointed sometimes. And the process of evidencing that last date in learning, after an audit and going back through and finding the information can be quite challenging. So, making sure you've got a system that will capture all of that in one place, just makes your life easier in the long run.
Paul Butler: Absolutely.
Kerry Linley: Anything else at stage one?
Paul Butler: Yeah, two more little things I had was understanding about engaging with the employers. So, in the planning of the program making sure that, there are obviously things like commitment statements and all those things fair enough, but they mean something. And that's about that engagement with the employer. It's about understanding what the program is and understanding what things like the 20% off the job are and things like that, so there are no surprises. So the program is effectively planned. If that’s done and agreed in the right way and that engagement with the employer is a good one and there's good dialogue and good planning and good ways of working, the apprenticeship will be fine - it's a great product. If it's not, then. There's a loss of trust. And as soon as you've got a loss of trust, you get disengaged learners, disengaged employers, and the whole thing falls apart and, and everybody loses out. So, there's that.
Kerry Linley: So, thinking about how you are going to engage with your employers before you start delivering is absolutely the right time.
Paul Butler: Yeah, absolutely. Because, and this is another point – why are you choosing the standards that you plan to deliver? So a provider saying well this generates £27,000 is not a reason to deliver that thing. So, you know, is it about where the jobs are? Is it where there are growth areas? So, this thing around intent for Ofsted at the strategic level I'll stress, so there's that. But it's actually understanding what you're delivering, why, where, and what sectors you're delivering and having the expertise. So, it all goes together, doesn't it, in terms of planning with the employer, making sure that the programs right, but actually you need expertise, don't you? So, your team need to be subject area experts, otherwise would you purchase that learning as an employer? And if you buy it through levy or just paying 5% contribution, you're still buying this thing now. S o therefore, you want value for money and you want someone who's got credibility to deliver that. So there's this thing about why are you choosing the standards you plan to deliver – and Ofsted will ask that question - and have you got the expertise to deliver that. It's all intertwined. Isn't it?
Kerry Linley: It is, yes.
Paul Butler: Because without proper planning, the whole thing falls apart, so it could be around compliance, it could be around the Ofsted side of it, it could be just simple engagement and planning with the employer or with the learner doing the initial assessment, you know, if you're get an initial assessment wrong and you don't evidence prior learning effectively, again, you could be challenged at audit.
Kerry Linley: Misuse of public funds again because you’re delivering something that shouldn't be delivered again, because it's been delivered in the past.
Paul Butler: Yeah. So, I've said all these things and I don't say that to scare people off, but they need to understand this before they go on to a register or apply for the register.
Kerry Linley: I think it's just about letting people know what the risks are so that they can mitigate against them and plan to deliver apprenticeships in the best way possible. It comes back to being a quality provider, doesn't it?
Paul Butler: Yeah, absolutely. And let's face it, without that job, without that employer, an apprenticeship doesn't exist anyway. So, therefore it should be absolutely inherent. It should be there. There's an old adage, that I was taught back in my retail days.
Kerry Linley: Is that the 6 P's?
Paul Butler: Yeah. But I won't say the the fourth one. Proper Planning Prevents PPPPP Poor
Kerry Linley: Absolutely.
Paul Butler: But you know what the other one is, don't you?
Kerry Linley: I do know what that other one is. It's not a bad swear word I don't think I'd kick you off the show if you said it.
Paul Butler: Yeah. But, there you go, there's a Pearl of wisdom for you.
Kerry Linley: Isn’t that a military phrase?
Paul Butler: I don't know, but back in my retailing days, many, many moons ago, my, old boss told me and the other one he told me was, ‘you can't sell fresh air son’, so there you go.
Kerry Linley: Well, let's hope that never happens.
Paul Butler: Yeah. Get those spuds on the shelf. Yeah.
Kerry Linley: Shall we move on to stage two?
Paul Butler: Yes. Yeah.
Kerry Linley: During delivery. So this is when, you've said it before, this is when the hard work really begins. So how does a great provider really start to deliver a service that underpins all of the fabulous work and thinking that went into the first stage? The stuff we've just been talking about.
Paul Butler: When I go through this part of it, I don't mean this in any particular order or precedence, so I've, I've listed down a few bullets to prompt me (because I've got Britain's worst memory in terms of what I'm thinking) so first of all, going back to understanding what an apprenticeship is. So understanding what you submitted, because don't forget many, many RoATP bids have been done for them or in conjunction with a lot of work done by a consultant. So actually, understanding and being able to deliver on what you submitted. That's the first thing.
Kerry Linley: So, take ownership of your application. Even if you have a consultant helping you with it, working on your behalf, actually understand what's being said in that application and own it.
Paul Butler: Absolutely. You know, otherwise, when it comes to first visits or first monitoring visit, it just falls apart. And again, you're doing a disservice to the clients where they could have engaged with a provider who gives them a good service. Another point I think is important is making sure you've got a competent team that covers all aspects. So, yes In terms of delivery, obviously I’ve already touched on subject experts being able to deliver confidently, using technology or being able to deliver to groups and actually understand subject matter. That's a given, but again, you know, you’ve still got to do it. But also on the other side, in terms of the back-up, the engine room as I call it, the administration and the quality and compliance side of it, making sure that they’re effective, and people understand it. And on that side of it, I suppose it's the same with delivery as well - be up to date with latest trends and guidance. So, for instance, if you're on delivery side, are you up to date with latest technology? So you're giving the best service. On the other side of the training provider, are you up to date with the latest guidance and, key things that are being noticed in Ofsted for instance, if you're on the quality side. Are you up to date with the latest safeguarding and prevent stuff? Are your policies up to date? But also more importantly, if you're looking at the financial side of it and compliance, are you up to date with the latest funding rules and the changes that are often happening?
Kerry Linley: So, are there any, useful resources that you could advise our listeners that they should be dipping into or checking in on regularly if you've got any pointers for them?
Paul Butler: Yes the ESFA updates. That’s a very simple thing to do to make sure that they get an alert via email.
Kerry Linley: So, you can register for those?
Paul Butler: Yeah, absolutely. So you can just Google it and they can register for that. Keeping tabs on all the funding, guidance, etc, and having a look, if you're on the quality side, have a look at most recent Ofsted inspections, making sure you're up to date with the latest Ofsted framework and you know, it sounds obvious, but some people if you're brand new and you haven't experienced Ofsted before or experienced an ESFA audit or haven’t had to deal with that type of data before, this is all new. So you don't know what you don't know. So those are some of those fundamental things that people need to understand. So, when I say about team competence, they need to understand those things. I'll tell you what is a good resource - I dunno how recently it's been updated, but there's the apprenticeship toolkit, the future apprenticeships toolkit, which was designed to assist providers in the transition from frameworks to standards but that covered a whole raft of things. It was almost like a ‘how to become a training provider’ fantastic resource and you know virtually all of it still applies nowadays. Things may be tweaked slightly because guidance changes, etc. but the principle remains the same.
Kerry Linley: We'll include some links to these different references that you've just mentioned in the transcript of the podcast so, people can access those at the end. Okay, so we've talked about making sure you've got the right team in place for all aspects of delivery, management, quality, etc. We've talked about technology. We've talked about making sure that you're up to speed with the latest guidance, checking on inspection reports. So, I think you can register to receive copies of any Ofsted inspection report can't you? So you can actually see what's happening when other providers are inspected.
Paul Butler: I believe so. I know it used to be able to.
Kerry Linley: I've had a few through this week.
Paul Butler: I just go into the site just because it's a curiosity thing. So, it's a habit for me, but I just go and have a look.
Kerry Linley: You need a different hobby.
Paul Butler: Yeah, I do, I do. I'm not going to say anymore because I'm not going to get dawned on that one.
Kerry Linley: Maybe that's a whole other podcast series?
Paul Butler: Yeah, the life and hobbies of Paul Butler. So another one is around making sure that the programs are fully planned with employers. I've already touched on that anyway, but again, it's obvious. To actually be able to come up with a decent program that fits the standard, but also fits the employer needs. So therefore it has to be planned properly and when I say planned it's not just about all the 20% and being compliant and making sure you meet the 12-month duration, that's critical, obviously, otherwise it's not fundable, but there's this thing about making sure that if you're an apprenticeship business you will want repeat business from that employer. So therefore, if you work closely with them and give them a good experience, they will come back for more and they will choose you. And then they will also ask you, can you deliver this for us. So, yeah, so that's important.
Kerry Linley: So that would be things like if you are delivering a Digital Marketing apprenticeship, making sure that what the tutor is teaching the learner is relevant to the job that the learner is doing in the workplace - so that it makes sense to the learner, the stuff that they're learning during training hours, they can apply that at their work, and it makes sense to the learner. So, it's about making the content relevant.
Paul Butler: Yeah, absolutely. And that's the thing around sequencing that Ofsted like as well, isn't it. So, making sure that whatever you're teaching them can be applied as soon as possible in the workplace so that they can embed those newly taught skills. I mean, that goes without saying anyway, but sometimes it doesn't happen because if you modularise things and you don't plan it effectively with the employer that learner may not be doing that aspect of it, in the sequence you want them to. So that's where the planning comes, it's really, really important.
Kerry Linley: I can imagine that's quite challenging for, you know, if you think about something like the Production Chef apprenticeship, if the training provider doesn't deliver the training in a way that reflects seasonality of produce - I can imagine that would be really challenging.
Paul Butler: Absolutely. Yeah. And that comes down to that core principle of planning the program with the employer, so and it applies to any occupation really. For instance, if you're doing something in construction, you would definitely need to understand a lot of the health and safety bit upfront, otherwise you’re endangering yourself, but can also become a liability to others in terms of their safety. So there are so many things and sequencing is so important, not just to tick a box with Ofsted, but actually if you think about it, sometimes it could be a bit around safety and actual efficiency of the program as well. So, there's so many reasons. This thing around proper planning with the employers is critical, particularly at the front-end, this thing around agreeing the price and prior learning, etc, etc, you could have a whole podcast on that in itself, and people make decent money out of advising on that type of thing and quite rightly so, because if you don't get it right, again you could be clawed back money, or you could get bombed out at Ofsted. That front end thing is so, so critical and that's part of planning, that whole front-end thing and and all this wonderful stuff we're talking about the most important thing is actually, are you delivering decent training because ultimately that's what Ofsted are looking for. Are they delivering, are you delivering decent training that impacts the learner positively? That's going to give them a good shot at having progression within their career and progression in their wider life, you know, and contributing to the economy and all those other wonderful things.
Kerry Linley: Okay. Anything else to consider at stage two?
Paul Butler: Yeah. Making sure there are no surprises, a simple thing. So that's with employers and learners. So, be upfront about the whole program. Again, we talk about the front end, but no surprises – that’s a simple one for me. Effective systems for QA and QI so your Quality Assurance and Quality Improvement programs - have you got an effective cycle that actually drives things forward and improves the learner experience? So again, it's not necessarily all about compliance, it’s actually, are you improving the experience of the learner and the employer to an extent as well, and therefore, if you are doing that and you are improving things and delivering a decent product, they will come back for more and your reputation goes up, you get more business from the jungle drums. So, so that's really important and that's basically down to effective systems and how you implement them and how people understand it and buy into it. On the technical side, the funding side, having a sound internal audit and understanding the rules and keeping up to date, I've already touched on that, but again, that's really important. And my final bullet point I've already said, so decent training delivered by experts. Use technology, utilise technology, particularly nowadays, you know, where much of the training has gone a hundred percent online, you know, it's going to be more and more blended from now on. So you'll see innovative use of technology, but don't go innovative for the sake of innovative. That all depends on the relationship with the employer and the learner.
Kerry Linley: It's about making sure that the process is fit for purpose, isn't it? And it's delivering a positive experience so that you do get employers coming back to you to deliver more apprenticeship training and the learners that you are delivering to have a positive experience and complete and achieve, which is ultimately what we're setting out to do in the first place.
Paul Butler: Yeah, absolutely. And the thing is, if the apprentice completes and achieves, chances are all the studies are out there about how much more productive they are in the economy and how much more they stand to earn, lifelong wages and things like that. So yeah, it's not so much about achieving a qualification now and, you know, an apprenticeship isn't a qualification anymore is it – you go through a process and you go through an experience - it's knowledge, skills, and behaviours, and it's a much more rounded person you get at the end of it. So, once you’ve completed an apprenticeship, you are a much more employable person, and hopefully you progress within that, that job, that company you're already with. If not, you’re better armed for a future career. And that's essentially what Ofsted are looking at. Yes they look at safeguarding and they look at all these other bits and bobs and you get the flavour of the month that they're looking at, etc. But essentially what they're looking at is that is the training provider providing impactful delivery on a learner that improves their life chances, you know, and that's essentially what it is.