Dean Cox

DAS secured after learner start date


We have scenarios where cohorts have been deleted (in error?) by the employer, so that we non-levy employers are reserving funds again after the learner has started. We understand that you are supposed to have funding from the start, and the current way we know to resolve this is to move the learners start date and taking into account any learning already taken for the funding, at a loss to the provider. However, this does impact the learner as they still need to be on programme for 12 months minimum from the new start date (with less work to undertake). Is there a way we can change information within the ILR retain the learner on the original start date and just receive funding from the point it was secured (fully aware we would still miss out on those initial months of funding)?

Thanks in advance.


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Steve Hewitt

No, in a word. Start date (month) needs to match DAS and Start and End need to be at least 365 days apart or they'll error in the ILR (unless it's a restart, which this isn't).

You really really need to get those reservations sorted before you start the learner, slightly worried that you're talking about "scenarios" plural... Everyone has the occasional one of these (even I had one last month!), but they should be super rare...

Dean Cox

Thank you Steveh, we are not putting anyone on programme without the cohort being reserved prior, but I am told we cannot send for final approval (to make it live) until the learner has actually started. There is then difficulties in getting the employer to approve (so it is stuck in a datalock), but for the odd learner the cohort has disappeared altogether (so the employer is deleting them whether on purpose or in error). If these are non-levy and have not given permissions then it is difficult to secure again in the same or nearby month. We're unsure of a failsafe way to protect ourselves from these scenarios. Thanks.

Steve Hewitt

Ooft, that sounds pretty gnarly.

I'm not sure about the final approval thing, hopefully others can chip in?

Ben James

You can definitely process it fully ('final approval') before the actual start date, because at that stage it's just classed as a commitment to fund the apprenticeship. It's essentially the reverse of what you're currently doing, in that you'll get a data lock until the service manages to match the learner to an ILR submission, but that's what's happening currently for you anyway, so you're no worse off. This way you can feel more assured that it's ready to go, and you're able to update pretty much anything on the record up until that learner match happens/the learner starts. 

Sadly there's not really any way to safeguard against the employer not doing their part in some way, you just have to keep on top of that relationship.

As for whether you can manipulate the start date so that you're taking the first bit on the chin (where the apprenticeship service hasn't been resolved until after the start), the answer is kind of 'no'. Reservations can only be used for 'new' starts, and you'd have to process it as a restart if you wanted to privately fund the first period. We had a very similar situation (almost identical in fact), where we privately funded the first period of training because of a delay in reserving funds, which the ESFA allowed in that particular instance, but they explicitly stated that it should not be common practice. 


Annabel Redshaw

We've had a couple of apprentices that have disappeared off the Apprenticeship Service Account - can employer's delete accounts so it takes the apprentice off the account?  It appears I think they must have been deleted when completed programme as we only go the DLOCK error after completion and I can't find them on the apprenticeship service account.

Roz Goodall

I don't think employers can delete funding records that have already been approved - I've just had a look on our employer/provider log in and can't see an obvious way to do it.

Dean Cox

In theory, can an apprenticeship be commercially funded FM99 for the period where DAS is not secured, and then negotiate the balance for the new remaining price from the month DAS was secured with FM36. Would this require a new set of ZPROG and AIM with TNP3 and TNP4. Or does this not work? Thanks.

Ben James

What you've described works as far as the ILR is concerned; it was how I did it (see: here). However, the ESFA said that whilst they were accepting of what I'd done as a one-off, it was not in what they considered to be 'the spirit of funding reservations', which should be used for new apprenticeships, not to partially fund restarted apprenticeships (which it would be in this case).