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No? Because Progress Reviews weren't mandatory until 1/8/22, so it's only for new starts this year, otherwise P59 and P60 would say "applies to all".
Also, can you ask your auditor what would happen if you *didn't* have signed ones every 12 weeks, what would they hypothetically do? The point being that, because Prog Reviews don't count as OTJ anyway, what is the sanction for not doing them?
audit feedback is in and response is as follows:-
"We note that this is a new requirement in the Funding. Whilst this does apply to learners enrolling before this date, the rules only applies for reviews completed after 1 August 2022 as this was not a requirement of the Funding Rules in prior years".
So applies to all reviews regardless of start date effective from the 1st August 2022.
Implications
"If progress reviews are not completed at least every 12 weeks, there is a risk that funding may be clawed back for periods in which no review can be evidenced".
Noticed in the 23/24 guidance that they have added this so it is definitely not clear in the 22/23 guidance.

Hmmmm, that's a pretty broad implication, also a pretty non-specific risk? [rhetorical] Which periods would be clawed back? All of the ones between reviews or just the ones after 12 weeks? What if the review was after 14 weeks but still in the same calendar month? Feels like "oh heck, we've got to put *something*, so we'll just be vaguely threatening"...
And, as you say, the changes in 23/24 kind of make it a bit pointless (not least because of all the ifs and buts around frequency from 1 August)...
I pressed further and this is the response.
P341 The evidence pack must include: P341.1 Evidence of progress reviews taking place in accordance with paragraphs P59 to P60 and the agreed outcome or actions of these reviews, including progress towards the training plan, signed by all three parties (apprentice, employer, provider)"
There is always the risk that funding could be affected if at audit it was found that the rules are not being followed.
There doesn't have to be a physical signed signature and other forms are acceptable please see the relevant excerpt form the Provider Funding Rules below.
"P357 We accept electronic evidence, including electronic / digital signatures. Where evidence is electronic, you must have wider systems and processes in place to assure you that apprentices exist and are eligible for funds."
You will still need an digital/electronic signature in place for the progress review. The best way to do this could be via email when you send round actions for the next review and each person could sign this electronically via email as this will demonstrate what was discussed in progress review and what needs to be done before next one.
It will be best to make sure that you have some sort of signature in place for these progress reviews, if any have been missed you could try and retrospectively get these signed by the employer.
Orlene Wilkes
Apprentice Progress Reviews Signed by Employers
Created
Would you say that signatures are required for all apprentice reviews regardless of the year they started effective from the 1st August 2022?
Just want a sanity check as currently being audited.