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I can definitely see the logic of 2.
I suppose my concern with it would be.. might the ESFA think we're manipulating the PED to realise a more favourable 'score' on the accountability framework. The learner was already past their PED on their original record, and now we're extending the duration even more with the hope that they'll achieve 'on time'. Obviously we'd annotate everything regardless, just thinking out loud.
We do 2. I just ask the apps team to record justification for the new date, and any further training should be clearly laid out in the Training Plan to support that. If they were already past their PED, I'd already expect the team to have re-planned the remaining delivery before they went on a BIL. I made the apps team a report and new form to complete when ESFA "clarified" that the app agreement has to cover the actual duration (para 54). It prompts them to re-plan the training and give me a new "estimated" end date that we record internally (all signed by the employer). All good evidence should they then go on a break.

Ben James
BIL after Planned End Date
Created
We've discovered an apprentice who went on a break in learning several months after their planned end date, and who is now returning on 31/10/23.
The usual practice of extending the original planned end date in line with the duration of the break will obviously not work in this case, as their return date will be after the newly extended planned end date.
What do people think the best course of action would be in this case?