EPAO changing prices midway through programme

If you're top of the band anyway, then ESFA don't want us to return costs above the band, so actually, you wouldn't need to change the TNP2s.

This still means you're taking the financial hit (and it's not a great way of doing business by this EPAO), but "at least" there's no admin burden...

Steve Hewitt but the compliance paperwork and ILR price would be inaccurate. We need to provide evidence on completion that EPAO payment has been made and we'd want this to match what costs outlined in the contract and financial schedule. 

Well you'll still be able to show a payment has been made (which is the key thing) *and* why it doesn't match?

P106.1 If the price you agree with the employer exceeds the maximum of the 
funding band, then you must agree off-line (outside of the ILR and 
apprenticeship service) how the employer will pay you any difference.
We do not need to know about the amount of this difference.

Steve Hewitt I keep telling our team that the TNP2 must exactly match the amount we pay the EPAO. Otherwise, it's a nonsense. If it isn't meant to represent that price, why do we even need to split the TNP? When we suddenly get an EPA discount last minute, we always reduce the TNP2 (and therefore total price). If we didn't, we'd essentially be stealing that discount from the employer! I would follow the same principle for increased EPAO costs, increase the TNP2. As you've said, since we're not supposed to report a combined TNP above band max, that does then involve reducing TNP1.

Remember that the EPA price is supposed to be negotiated between employer and EPAO. We know that doesn't often happen in reality, but it is technically not a lot to do with the provider. If the employer agreed a training price with the provider, and confirmed the the price they planned for the provider to pay the EPAO, surely the employer should pay the extra EPAO cost from their own pocket? It was their responsibility to agree that with the EPAO, and they didn't, or they just assumed it would be ok. If they did agree a price with the EPAO, the EPAO shouldn't just increase that after it was agreed. 

I would change TNP 2 and therefore TNP1, and decide whether you want to charge the employer the difference, or take a hit on your earnings.

But (and we're not really arguing here, just to be clear, I'm just laying out the counter-argument), there's no reduction to our delivery costs for TNP1 in this circumstance (which, obviously, we've all got fully costed out from the start), so why would we reduce it?

The audit question about EPAO at no point asks an auditor to compare the values back to TNP2, just that they can see they've been paid... Does this make it pointless? Far be it from me to say...

The new rule about not recording combined TNP above band max is the culprit here. Why did they do that, what was the problem with declaring above? I would like to report the prices we actually agreed, I don't want to have to record a fake value in either TNP1 or TNP2, but here we are. 

The reason I'm strict on TNP2 and EPA payment matching, is because I suspect one day auditors will ask. Also, I did find examples of where we'd had a late reduction in EPA price (sometimes multiple student discounts we couldn't have predicted), and nobody thought to reduce the overall price. That then just means the provider has just had a cash bonus from the employer and/or ESFA. That's not ok. You can't take that money without formally re-agreeing a higher training price with the employer, which of course they're not going to do. My guess is that this is happening all over the place, and nobody knows, because they're not checking EPA payment vs TNP2. I don't even think the providers realise they're taking more money than they should. I didn't know because nobody told me the EPA price went down. The people knew that knew the price went down, had no concept of what that meant to our income. That's why I am picky about it. I'd rather artificially reduce the TNP1, as it has no consequence. Putting in a TNP2 we know to be wrong, means I can't check on disparities between what we thought we were paying the EPAO vs what we actually paid them.

Why did they do that, what was the problem with declaring above?

I guess a bit of fiscal responsibility? Forcing you to only declare (at most) the maximum via TNP1+TNP2 means you're forced to only ever declare that much in DAS, unless you fancy a data lock. Previously (if memory serves) DAS would just whinge and say "this is over the funding band max, are you sure?" to which people would say "of course I'm sure", and that's that. This way, you can charge over the funding band outside of the service if you want, but not via DAS. Seems to be a great deal of talk lately about public funds not being used "properly", so I guess this is in line with that. Sort of.

@... That does make sense, but it does also then force us to enter false data, and nobody knows whether to make the training or the EPA price wrong. If there was just a single lump TNP, it wouldn't matter, but then we're back to my point about providers taking more money than they agreed, and that being tough to spot.

Ruth Canham-James

It does, which I agree is daft, particularly when you consider the first and second data management principles of the ILR are all about the information being accurate and reflective of reality. They could, I'm sure, quite easily add extra fields and options to account for all of these scenarios, but the house of cards being what it is.. I'm not entirely sure the pros would outweigh the potential cons. We're still calling it the Achievement Date for God's sake.. and how easy is that to fix?

(wait til they bring back A32 for Guided Learning Hours for AEB in 24/25, then we'll have three different hours fields...)