Awarding Organisations (AO’s) have confirmed that they will not Quality Assure any non- accredited training as part of their End Point Assessment (EPA) plans, thereby firmly placing the responsibility for quality and compliance with the employer.

Simultaneously, the Care Quality Commission (CQC) has recently issued revised guidance to inspectors: CQC Brief guide – Care Certificates’ guide to gathering evidence’ placing greater emphasis on reviewing and checking the quality of Care Certificate training. Key to the guide is the emphasis on inspectors rigorously checking the evidence of Care Certificate training, requesting access to tracking and reporting as well as speaking with employees to ascertain their knowledge and understanding. Apart from the obvious potential to impact upon the CQC inspection reports themselves, discovery of any potential issues could trigger the possibility of ‘SFA financial clawback’ implications as detailed above.

The most obvious anomaly created by the new Apprenticeship standards is the fact that mandatory training i.e. Care Certificate can now be publicly funded, something that has always been disallowed under previous SFA funding regimes. However, employers must remain vigilant that they do not allow ‘programme creep’ to occur and unwittingly utilise approved funding to fund non-approved learning and development. With specific reference to the Care Certificate, employers need to be 100% confident in their current content, delivery and assessment process, including their ability to record and evidence individual learner records (ILR). They also have to be fully confident that their training providers are fully compliant to ensure they do not inadvertently become embroiled in time-consuming and potentially expensive audits and inspections leading to ‘financial clawback’.