Audit Report City & Guilds 21 February 2018 and 22 February 2018
Contents 1 Background 1 1.1 Scope 1 1.2 Audit Report and Action Plan Timescales 2 1.3 Summary of Audit Issues and Recommendations 3 1.4 Risk Rating of Issues 7 2 Detail of Audit Issues and Recommendations 8 2.1 Issues 8 2.2 Recommendations 14 3 Acceptance of Audit Findings 18 Scottish Qualifications Authority 2015 (Version 9)
1 Background This was the twelfth audit of City & Guilds since it was approved as an awarding body by SQA Accreditation in 1995. City & Guilds is a nationally recognised awarding body whose services include providing and delivering qualifications across a wide variety of industry sectors. Its headquarters are at Giltspur House, 1 Giltspur Street, London, EC1A 9DD. 1.1 Scope SQA Accreditation carries out quality assurance activity in line with its Quality Assurance of Approved Awarding Bodies Policy. This policy states the type and frequency of our quality assurance activities, describes our reporting procedures, and indicates how the awarding body s Quality Enhancement Rating is calculated. This was a scoped audit of City & Guilds based upon but not limited to the areas identified within SQA Accreditation s awarding body audit and provider monitoring strategic plan for 2017 18. The audit included aspects of the awarding body s operational activities in respect of Regulatory Principles 1, 8, 11, 14 and 15. In addition to the above, aspects of the awarding body s systems and procedures in respect of the review and maintenance of SQA accredited qualifications, covered by Regulatory Principles 9 and 10, were included within the scope. Our quality assurance activities are conducted on a sampling basis and, consequently, not all aspects of the awarding body s systems, procedures, and performance have been considered to the same depth in this report. SQA Accreditation audit reports are written by exception, focusing only on those areas where corrective action is required or recommended. Consequently, this audit report does not detail areas where compliance or good practice was found. The audit was designed to ensure City & Guilds complies with SQA Accreditation s regulatory requirements, namely: SQA Accreditation s Regulatory Principles (2014) all Regulatory Principles Directives the awarding body s Accreditation Licence Awarding body documentation considered for review by the audit team includes all documents banked on City & Guilds SharePoint site at the time of audit, and information supplied to support audit activity. Restricted or commercially sensitive information gathered during SQA Accreditation s quality assurance activities is treated in the strictest confidence. Scottish Qualifications Authority 2015 (Version 9) 1
1.2 Audit Report and Action Plan Timescales City & Guilds: audit date: 21 & 22 February 2018 Audit Report approved by Accreditation Co-ordination Group on: 2 May 2018 Audit Report to be signed by City & Guilds: 15 June 2018 Action Plan to be e-mailed to regulation@sqa.org.uk by City & Guilds: 15 June 2018 The process will apply in relation to the timescales specified above: The awarding body will be sent two signed copies of the Audit Report by post. The awarding body must sign both copies of the Audit Report and return one by post to SQA Accreditation in accordance with the timescale specified above. The awarding body will also be e-mailed a copy of the Audit Report (for information only) and an electronic copy of the Action Plan. The awarding body must complete and return the Action Plan in accordance with the timescale specified above and e-mail this in Microsoft Word format to regulation@sqa.org.uk. SQA Accreditation will confirm when the Action Plan is appropriate to address the Issues and present it to Accreditation Co-ordination Group (ACG) for approval. Following approval by ACG, the awarding body will be sent two signed copies of the approved Action Plan by post. The awarding body must sign both copies of the Action Plan and return one by post to SQA Accreditation. The findings of this Audit Report and the associated Action Plan will be published on SQA Accreditation s website following signed agreement. SQA Accreditation will continually monitor progress towards completion of the proposed actions identified in the Action Plan and update the awarding body s Quality Enhancement Rating as appropriate. Scottish Qualifications Authority 2015 (Version 9) 2
1.3 Summary of Audit Issues and Recommendations An Issue has been recorded where evidence shows that the awarding body is not compliant with SQA Accreditation s regulatory requirements. The awarding body must address the Issues and specify corrective and preventative measures to address them through its Action Plan. The Action Plan is e-mailed to City & Guilds as a separate document to the Audit Report, and must be submitted to SQA Accreditation in accordance with the timescale specified in 1.2. As a result of the audit and post-audit activities, five Issues have been recorded and six Recommendations have been noted. Issue Detail of Issue recorded Risk rating 1. Principle 5 The continued use of the Institute of Leadership & Management (ILM) logo on policy, procedural, and guidance documentation with in certain instances the separation and duplication of particular functions, is not in the spirit of the original condition set by ACG, and allows the ILM brand to retain precedence over that of the awarding body. 2. Principles 6 and 8 In respect of the Domestic Natural Gas qualifications, City & Guilds representatives were not aware of any current or lapsed partnership arrangement with SQA Awarding Body. Medium Low Checks revealed that, as far back as August 2015, SQA Awarding Body was aware of a partnership agreement, albeit potentially lapsed, in respect of these qualifications. The lapsed status of the partnership agreement was confirmed through a City & Guilds amendment submission for the two remaining qualifications, G956 23 and G95A 23, which was approved by ACG on 26 October 2016. The lack of awareness that such a partnership agreement existed would indicate that information/records held by City & Guilds may not be as complete as they should be. Scottish Qualifications Authority 2015 (Version 9) 3
3. Principles 6, 15 and RPDIR 2 City & Guilds allocation of a finite registration period and subsequent re-registering of candidates when required, would appear to have become conflated with the process of formally registering a candidate for an SQA accredited qualification. Consequently, such reregistrations are being reported as new candidate registrations within the quarterly data submissions to SQA Accreditation. This would indicate the possibility of duplicate registrations, and may lead to inaccurate registration data. High 4. Principles 6 and 15 City & Guilds data return of 12 January 2018 contained evidence of 25 candidate certifications for the SVQ 2 in Hairdressing at SCQF Level 5, G9G2 22, after the certification end date of 31 July 2017. High There was no available evidence provided as part of the audit to support the awarding body s decision to certificate candidates beyond the existing certification end date and no evidence of referral to SQA Accreditation for approval. 5. Principle 14 City & Guilds has an appropriate understanding of the need to investigate cases of suspected malpractice and maladministration. However, there remains a lack of understanding of the need to identify cases of all suspected malpractice and maladministration to SQA Accreditation upon discovery and as a matter of course. Low Scottish Qualifications Authority 2015 (Version 9) 4
A Recommendation has been noted where SQA Accreditation considers there is potential for improvement. The awarding body is advised to address any Recommendations noted as good practice. However, measures to correct or prevent these are not mandatory and therefore do not form part of the Action Plan. Recommendation Detail of Recommendation noted 1. Principle 7 City & Guilds may wish to consider the relevant Category Manager liaising with SQA s team of Accreditation Managers to ensure that there is a current and ongoing understanding of the awarding body s business objectives in respect of SQA accredited qualifications. 2. Principle 9 Given the stated intention to review the document Developing, submitting and maintaining qualifications and learning programmes for Scotland SCQF and SQA Accreditation/SCQF, February 2018, Version 2.2, City & Guilds may wish to submit the subsequent version for consideration by SQA Accreditation to ensure that it fully meets the requirements of this regulatory principle. 3. Principle 15 In respect of late registrations within the lapsing period for accredited qualifications, City & Guilds may wish to ensure that there exists a strong rationale agreed by both the provider and the awarding body for such registrations, and that there is sufficient input from relevant external quality assurance staff in approving and monitoring progress around this. Moreover, City & Guilds should ensure that candidates have adequate time to complete the award by the relevant certification end date. Lastly, it may wish to ensure that the qualification regulator is notified when such scenarios occur. This will allow for appropriate quality assurance checks as part of any provider monitoring activity to be undertaken. 4. Principle 15 Prior to the audit, SQA Accreditation received a copy of Closed Qualifications Work Flow (SQA Requests), Version 4.2, 10 May 2016, as evidence of how City & Guilds manages requests for late certifications. The awarding body may wish to revise this document, to ensure all such requests are directed to the relevant Regulation Manager within SQA Accreditation for consideration and not the Head of Accreditation as currently stated. Scottish Qualifications Authority 2015 (Version 9) 5
5. Principle 15 City & Guilds may wish to ensure that the Customer Service team is aware of SQA Accreditation s Regulatory Principles Guidance Note Principle 15 Requesting Certification for Expired Qualifications, June 2017, which gives current guidance about late certification. 6. Principle 15 and RPDIR 3 Prior to the audit, City & Guilds provided SQA Accreditation with a copy of its Certificate re-brand rollout plan, dated 19 February 2018, and a copy of the associated Certificate info sheet which explained the new format of certificates to be implemented as of 19 March 2018. City & Guilds is currently in the process of re-branding its certificates. Given the different types of qualifications that hold accredited status, it may wish to consider the submission of new certificate exemplars to SQA Accreditation for review to ensure compliance with RPDIR 3. Scottish Qualifications Authority 2015 (Version 9) 6
1.4 Risk Rating of Issues SQA Accreditation assigns a rating to each Issue recorded, depending on the impact on or risk to the awarding body s operations, its SQA accredited qualifications and/or the learner. Issues recorded during the audit will count towards City & Guilds Quality Enhancement Rating which will, in turn, contribute towards future quality assurance activity. Further detail on how the Quality Enhancement Rating is calculated can be found on the SQA Accreditation website. Scottish Qualifications Authority 2015 (Version 9) 7
2 Detail of Audit Issues and Recommendations The following sections detail Issues recorded and Recommendations noted against SQA Accreditation s regulatory requirements. 2.1 Issues Regulatory Principle 5. The awarding body shall provide clear information on its procedures, products and services and ensure that they are accurate and appropriate to SQA accredited qualifications. A number of documents reviewed by the audit team contained references to the Institute of Leadership and Management (ILM), either through the presence of an organisational logo and/or specific references to separate functions within a number of specific documents. For example, the Investigation Policy, Version 2.1, January 2015, is dual branded with both the ILM and City & Guilds logos at present and mentions both organisations separately at each stage of the policy, including different communication routes for reporting potential suspected malpractice. As noted in Issue 4, the audit team is unsure of the status of this document, given the date of the current version, but it was available on the awarding body s website at the time of the audit. Other documentation, such as the Access Arrangements When and How Applications Need To Be Made to City & Guilds, Version 2.1, October 2016, the Feedback and Complaints Policy, Version 1.2, September 2017; and Managing Cases of Suspected Malpractice on Examinations and Assessments, Version 6.1, Jan 2018, all indicate separate approaches to their respective functions for leadership and management qualifications. SQA Accreditation no longer recognises ILM as an SQA approved awarding body, as it was de-approved on 20 April 2016, following City & Guilds request of December 2015. An amendment/extension submission transferred the relevant Team Leading and Management qualifications to City & Guilds as of 3 February 2016. As part of ACG s approval of the amendment and extension, the following condition was set: That only City & Guilds branding can be used on promotional, supporting documentation, and material for the suite of amended qualifications. City & Guilds will be asked to demonstrate that this has been achieved and provide this evidence to SQA Accreditation by 31 March 2016. ILM has subsequently been described as a City & Guilds Group Business Unit, which sits within the awarding body. The creation of such a business unit, representing a retention of staff, knowledge, and expertise in all aspects of the administration of the leadership and management qualifications within City & Guilds, is a valid approach. Scottish Qualifications Authority 2015 (Version 9) 8
However, the continued use of the ILM logo on policy, procedural, and guidance documentation with in certain instances the separation and duplication of particular functions, is not in the spirit of the original condition set by ACG and allows the ILM brand to retain precedence over that of the awarding body. This has been recorded as Issue 1. Regulatory Principle 6. The awarding body and its providers shall maintain accurate documents, records and data. And Regulatory Principle 8. The awarding body shall ensure that SQA Accreditation is granted access to all information pertaining to SQA accredited qualifications. As part of the audit, SQA Accreditation sought evidence of how City & Guilds managed partnership arrangements in respect of the delivery of SQA accredited provision. In particular, the audit team sought evidence of partnership working in respect of accredited provision for Domestic Natural Gas Installation, delivered in partnership with SQA Awarding Body, as well as the Scottish Certificate for Personal Licence Holders (SCPLH) qualifications delivered in partnership with Alcohol Focus Scotland. The audit team were unable to see evidence of either partnership agreements during the audit, but a copy of the agreement with Alcohol Focus Scotland was provided for review post-audit. This agreement clearly delineated the respective roles of both partners in relation to all aspects of qualification delivery. In respect of the Domestic Natural Gas qualifications, City & Guilds representatives were not aware of any current or lapsed partnership arrangement with SQA Awarding Body. SQA Accreditation s listing and lapsing reports noted four qualifications relating to Domestic Natural Gas qualifications, which appeared to be covered by a partnership agreement with SQA Awarding Body: SVQ 3 in Domestic Natural Gas Installation, G958 23 SVQ 3 in Domestic Natural Gas Emergency Service Operations (ACS), G95D 23 SVQ 3 in Domestic Natural Gas Installation and Maintenance (ACS), G95A 23 SVQ 3 in Domestic Natural Gas Maintenance, G956 23 The audit team agreed to undertake further checks post-audit to ensure that the information regarding these qualifications being offered through a partnership arrangement was correct. The checks revealed that, as far back as August 2015, SQA Awarding Body was aware of a partnership agreement, albeit potentially lapsed, in respect of these qualifications. At this time, it communicated with City & Guilds over a possible withdrawal submission for two of the qualifications, as well as an extension request for the remaining qualifications. Scottish Qualifications Authority 2015 (Version 9) 9
The lapsed status of the partnership agreement was confirmed through a City & Guilds amendment submission for the two remaining qualifications, G956 23 and G95A 23, which was approved by ACG on 26 October 2016. While this submission confirms that the termination of the partnership agreement with SQA Awarding Body had no operational impact on the delivery of the qualifications, the apparent lack of awareness that such a partnership agreement existed would indicate that information/records held by City & Guilds may not be as complete as they should be. This has been recorded as Issue 2. Regulatory Principle 6. The awarding body and its providers shall maintain accurate documents, records and data. Regulatory Principle 15. The awarding body and its providers shall have effective, reliable and secure systems for the registration and certification of learners. And Regulatory principles Directive RPDIR 2 Data Submissions A review of the awarding body s most recent data return to SQA Accreditation prior to the audit, submitted on 12 January 2018 and covering the period 1 October to 31 December 2017, highlighted a number of concerns regarding late registrations and certifications. A number of late registrations were highlighted in respect of the SVQ 2 in Hairdressing at SCQF Level 5, G9G2 22, which lapsed on 31 July 2015, as well as the following Diplomas, all of which lapsed on 30 November 2016: Diploma Light Vehicle Maintenance and Repair Principles at SCQF Level 5, R171 04 Diploma in Light Vehicle Maintenance and Repair Principles at SCQF Level 7, R172 04 Diploma in Heavy Vehicle Maintenance and Repair Principles at SCQF Level 5, R173 04 Diploma in Heavy Vehicle Maintenance and Repair Principles at SCQF Level 7, R174 04 The existence of late registrations does not constitute a compliance issue as such, but the rationale provided to SQA Accreditation s Information Assistant as a reason for the registrations in question against the various Diplomas is a concern, as they have been described as a form of re-registration of the candidates on the basis that their original registrations had expired. Consequently, the audit team discussed this and sought clarification on the process of reregistration, and the apparent expiry of initial candidate registrations. City & Guilds representatives advised that all candidates are registered within the awarding body s learner management system for a fixed period of three years. Three years constitutes the average length of time that the awarding body believes is normally required for a candidate to complete a qualification. Scottish Qualifications Authority 2015 (Version 9) 10
The purpose of this fixed registration period is to allow both the awarding body and provider to track progress towards candidate achievement, and can be renewed should the candidate require more time to complete, or a specific qualification is considered to have an average completion time greater than the initial three years. However, although the process of allocating a finite registration period and subsequently reregistering candidates when required is an internal awarding body process to support operational requirements, it would appear that it has become conflated with the process of formally registering a candidate for an SQA accredited qualification, resulting in such reregistrations being reported as new candidate registrations within the quarterly data submissions to the qualification regulator. The available evidence would therefore indicate the possibility of duplicate registrations, leading to inaccurate registration data. This has been recorded as Issue 3. Regulatory Principle 6. The awarding body and its providers shall maintain accurate documents, records and data. And Regulatory Principle 15. The awarding body and its providers shall have effective, reliable and secure systems for the registration and certification of learners. The same data return of 12 January 2018 also contained evidence of 25 candidate certifications for the SVQ 2 in Hairdressing at SCQF Level 5, G9G2 22, after the certification end date of 31 July 2017. When SQA Accreditation s Information Assistant sought a rationale for the volume of late registrations against this particular qualification, the awarding body acknowledged that it had failed to adhere to its own documented workflow process with regard to seeking certifications for closed qualifications, which notes the need to seek SQA Accreditation approval for such certification requests. Given concerns regarding the volume of late certifications against this particular qualification, the audit team indicated that this would be an area for discussion during the audit. City & Guilds representatives were content to discuss the situation, noting that they were of the opinion that Habia had approved the late certifications in question. During the audit discussions, City & Guilds representatives indicated that the issue primarily revolved around a decision to either extend or undertake a full re-accreditation of the current SVQ in Hairdressing, bearing in mind that the qualification was a mandatory component of the Habia Modern Apprenticeship Framework for Hairdressing, the review of which had been subject to some delay. This delay resulting in possible funding implications for providers and candidates. Scottish Qualifications Authority 2015 (Version 9) 11
City & Guilds chose to fully re-accredit the qualification based upon a belief that the Modern Apprenticeship Group had agreed that candidates undertaking the Modern Apprenticeship could register on the existing Hairdressing SVQ, despite it entering its lapsing period in July 2015. SQA Accreditation s Accreditation Co-ordination Group (ACG) approved such an approach on 1 July 2015 as follows: Members agreed that these qualifications would Dual Run with the original qualifications for one month until 31 July 2015. This will allow candidates undertaking the Modern Apprenticeship Framework to be registered. The audit team fully appreciated the difficulties that such a scenario presented but were unable to determine anything from the conversations that indicated that permission had been granted to extend the certification end date. It was pointed out to City & Guilds representatives that this could only have occurred if the awarding body had sought to extend the accreditation period of the existing SVQ and that this had been approved by ACG. The audit team were not provided with copies of correspondence that City & Guilds believed supported its position on the late certification issue during the audit itself. However, copies were subsequently submitted to the audit team for consideration. A review of this evidence, alongside a comparison with correspondence held by the relevant Accreditation Manager, confirmed that all parties accepted that candidates could be registered on the existing Hairdressing SVQ within the relevant lapsing period, as an exceptional circumstance. However, the correspondence but did not provide support for the awarding body s decision to certificate candidates beyond the existing certification end date without recourse to the qualification regulator for approval. This has been recorded as Issue 4. Regulatory Principle 14. The awarding body and its providers shall ensure that it has safeguards to prevent and manage cases of malpractice and maladministration. Pre-audit checks found no evidence of the awarding body identifying instances of suspected or actual malpractice or maladministration since the last SQA Accreditation audit. At the audit, City & Guilds representatives confirmed that they were unaware of any instances of malpractice and maladministration in respect SQA qualifications. As part of the review of the awarding body s policy and practices around malpractice and maladministration, the audit team was provided with an overview of the staff resources allocated to handling cases of malpractice and maladministration, as well as the process to be undertaken. During this conversation, it became apparent that awarding body representatives were still unclear on the need to identify cases of suspected malpractice or maladministration to the qualification regulator as they are discovered. Scottish Qualifications Authority 2015 (Version 9) 12
A pre-audit review of documentation available on both SharePoint and the awarding body s website would seem to support this lack of understanding. For example, a review of the document Managing Cases of Suspected Malpractice on Examinations and Assessments, Version 6.1, January 2018, contained a statement to the effect that information concerning an investigation into suspected malpractice may also be shared with the regulatory authorities. Again, the document notes that City & Guilds may also notify the regulator and any other appropriate authorities, if it is found through investigation that certificates issued from the centre are invalid. Under the heading Assessment Practice in the awarding body s website, the audit team noted a link to a document titled Investigation Policy, Version 2.1, January 2015. The status of this policy is not clear as it is not referenced in Managing Cases of Suspected Malpractice in Examinations and Assessments, Version 6.1, January 2018. Allied to this fact, although the policy outlines the steps the awarding body will take in responding to and investigating an allegation of suspected malpractice, it does not make any reference to the need for referral to the qualification regulator. While it is clear from the available documentation that City & Guilds has an appropriate understanding of the need to investigate cases of suspected malpractice and maladministration, there remains a lack of understanding for the need to identify cases of all suspected malpractice and maladministration to SQA Accreditation upon discovery and as a matter of course. This has been recorded as Issue 5. Scottish Qualifications Authority 2015 (Version 9) 13
2.2 Recommendations Regulatory Principle 7. The awarding body shall have effective arrangements for communicating with its staff, stakeholders and SQA Accreditation. The current City & Guilds Category Manager, who has responsibility for the development of products and services across the UK, was unable to take participate in discussions around the awarding body s future business objectives in Scotland and current SQA accredited provision, due other commitments. Nonetheless, the audit team believes that there may be value in the Category Manager liaising with SQA s team of accreditation managers to ensure that there is a current and ongoing understanding of the awarding body s business objectives in respect of SQA accredited qualifications. This has been noted as Recommendation 1. Regulatory Principle 9. The awarding body shall ensure that it has robust systems and processes for the identification, design, development, implementation and review of qualifications, which meet the needs of users. Prior to the audit, SQA Accreditation s team of accreditation managers highlighted a number of ongoing concerns regarding the quality of accreditation submissions received from City & Guilds. The concerns ranged from late and retrospective requests for extensions, failure to submit withdrawal requests, as well as a general lack of awareness of SQA Accreditation s process for accrediting qualifications and where sector responsibility sat within the accreditation management team. Overall, the accreditation managers felt that there was lack of awareness, on their part, of City & Guilds business objectives in Scotland and any consequent impact upon accredited provision. It was also felt that the awarding body staff making accreditation submissions seemed unaware of the awarding body s overall objectives beyond the specific submissions and therefore, were unable to provide context for a range of submissions particularly in respect of extensions and withdrawals. Prior to the audit, the audit team reviewed the awarding body s Qualification Development Process, Version 1.2, June 2016, which was available on SharePoint. Although comprehensive in terms of content, the document appeared to be very Ofqual focussed, making no direct reference to the role of SQA Accreditation, the process of seeking qualification accreditation, and contained only a single reference to the Scottish Credit and Qualifications Framework (SCQF) in the introduction. Scottish Qualifications Authority 2015 (Version 9) 14
Given the concerns around the standard of accreditation submission and the lack of knowledge of the accreditation process amongst City & Guilds staff, the audit team were somewhat concerned that this document appeared to be key in supporting the design, development, and implementation of qualifications. These concerns were enhanced by the inclusion of a link to an Ofqual webpage explaining how to use their systems with no comparable link to SQA Accreditation. However, shortly before the audit, SQA Accreditation received a document entitled Developing, submitting and maintaining qualifications and learning programmes for Scotland SCQF and SQA Accreditation/SCQF, February 2018, Version 2.2. This document was not previously available on SharePoint and some time was spent at the audit discussing its content with the members of Industry and Products team responsible for SCQF and accreditation submissions. City & Guilds representatives noted that the document was under review, and the audit team suggested a number of possible additions and amendments for consideration, including appropriate references to the Qualification Development Process, Version 1.2, June 2016. However, from an SQA Accreditation/SCQF perspective, the audit team consider this document to be a marked improvement on the previously mentioned Qualification Development Process, Version 1.2, June 2016. Alongside the stated intention of the Industry and Products team to re-focus its attention on Scotland and the refreshed Product Review Process, which was outlined at the audit, there is an opportunity for City & Guilds to address the concerns of SQA Accreditation in this area. Lastly, given the stated intention to review the document Developing, submitting and maintaining qualifications and learning programmes for Scotland SCQF and SQA Accreditation/SCQF, February 2018, Version 2.2, City & Guilds may wish to submit the subsequent version for consideration by SQA Accreditation to ensure that it fully meets the requirements of this regulatory principle. This has been noted as Recommendation 2. Regulatory Principle 15. The awarding body and its providers shall have effective, reliable and secure systems for the registration and certification of learners. As noted in respect of Issue 3 above, a review of registration data indicated a number of late registrations within the lapsing period in respect of accredited qualifications. Although such registrations do not amount to a compliance issue as such, SQA Accreditation encourages awarding bodies to support late registrations only in exceptional circumstances. City & Guilds provided copies of a Pre-Request Checklist, the Business Rules for Closed Qualifications which is referenced in the document Closed Qualifications Work Flow (SQA Requests), Version 4.2, 10 May 2016 as well as a sample from the Closed Qualifications Restricted List, as evidence of how the Customer Service team will manage such requests. Scottish Qualifications Authority 2015 (Version 9) 15
While recognising that this constitutes a basis for successfully managing late registrations, the awarding body may wish to consider further enhancements to the process. This may include ensuring that there exists a strong rationale agreed by both provider and awarding body for such registrations, and that there is sufficient input from relevant external quality assurance staff in approving and monitoring progress around said rationale. Despite a statement to the contrary within the Pre-Request Checklist, the aim of this process should not be to ensure that SQA know to expect a late certification but to focus on ensuring sufficient time is available for the candidate to complete the award by the relevant certification end date. Although City & Guilds does not require permission from SQA Accreditation to allow late registrations, it may wish to ensure that the qualification regulator is notified when such scenarios occur. This would allow for appropriate quality assurance checks as part of any provider monitoring activity to be undertaken. This has been noted as Recommendation 3. During pre-audit discussions regarding Issue 4 in respect of late certifications, SQA Accreditation was provided with a copy of a document titled Closed Qualifications Work Flow (SQA Requests), Version 4.2, 10 May 2016, as evidence of how City & Guilds manages requests for late certifications. The document indicates that a key stage of the process is for a member of the Customer Service team to seek approval for late certification requests from the Head of Accreditation in SQA Accreditation. This is incorrect and the awarding body may wish to update the document to reflect that fact all such requests should be directed to the relevant Regulation Manager within SQA Accreditation for consideration. This has been noted as Recommendation 4. As noted within Issue 4, City & Guilds acknowledged that it had failed to comply with SQA Accreditation guidance around requests for late certification of candidates. The audit team acknowledges that immediate steps were taken by the awarding body to address the issue prior to the audit date to rectify this failing by re-establishing the use of the form Awarding Body Request for Late Certification, April 2017, Version 1, devised by the qualification regulator for this purpose. However, the information provided within the forms lacked sufficient detail; included inaccurate accreditation dates and qualification codes provided at the point of accreditation, and the supporting rationales lacked clarity and robustness. Scottish Qualifications Authority 2015 (Version 9) 16
Wishing to remain supportive of the awarding body s attempts to resolve the matter quickly, the audit team discussed the need for accuracy with City & Guilds representatives during the audit. With this in mind, the awarding body should ensure that the Customer Service team are aware of SQA Accreditation s Regulatory Principles Guidance Note Principle 15 Requesting Certification for Expired Qualifications, June 2017, which constitutes the current guidance in this area. This has been noted as Recommendation 5. Regulatory Principle 15. The awarding body and its providers shall have effective, reliable and secure systems for the registration and certification of learners. And Regulatory principles Directive RPDIR 3 Logos and certificate requirements for SQA accredited qualifications Prior to the audit, City & Guilds provided SQA Accreditation with a copy of its Certificate rebrand rollout plan, dated 19 February 2018, and a copy of the associated Certificate info sheet which explained the new format of certificates to be implemented as of 19 March 2018. Given the different types of qualifications that hold accredited status, City & Guilds may wish to consider the submission of new certificate exemplars to SQA Accreditation for review to ensure compliance with RPDIR 3. This has been noted as Recommendation 6. Scottish Qualifications Authority 2015 (Version 9) 17
3 Acceptance of Audit Findings For and on behalf of City & Guilds: Print name For and on behalf of SQA Accreditation: Print name... Signature ANDREW CRONE... Signature... Designation... Designation... Date SENIOR ACCREDITATION MANAGER... Date... 03/05/2018... Scottish Qualifications Authority 2015 (Version 9) 18