Paul Blackshaw

OTJT hours calculator

Created

Just curious to know if anyone else has noticed that the ESFA's minimum OTJT hours calculator appears to round the planned duration to the nearest whole week and therefore produces some unexpected results? 

Eg. a duration of 368 days is rounded up to 53 weeks, generating a minimum requirement of 284 OTJT hours.  

In view of the method defined in the Funding Rules, I've asked the Helpdesk if they consider the calculator to be correct? That was over 6 weeks ago. 

My concern is whether this 'new' calculation of minimum hours will be used by the ESFA to check the compliance of programmes previously calculated without any rounding. I appreciate the difference only amounts to a handful of hours, but it's significant if it ultimately decides whether a programme is eligible for funding or not. 

Replies

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Martin Locock

Yes this triggered some FRM37 validation errors in our VYED data on some long (5 year) programmes.

Connor Goulding

Hi Paul, did you ever get a response regarding this? I've noticed the same and have put a similar case in with the helpdesk but yet to hear back.

This is causing us to have records on FRM37 and cannot find any mention in the funding rules that the ESFA expect you to round within the calculation, so feel like we should not be penalized for this.

Paul Blackshaw

The helpdesk escalated this to their specialist support team. They replied last week to confirm they believe the published calculator is correct because the rounding of the planned duration is defined in the published OTJ guide, paragraph 84, which states “Note that in the calculation the start point (duration) and the end point (minimum number of off-the-job training hours) are rounded up or down to a full number. Statutory leave is not rounded.” 

I've replied expressing my concern that rounding is not stated in the funding rules. I've also questioned why rounding ever needed to be applied because, in a mathematical context, it's failing to correctly determine the 20% minimum based on the apprentice's normal working hours (capped at 30 hrs/wk if applicable and less stat leave). 

Here is the explanation I received with an example where the duration is rounded up from 52 weeks and 4 days to become 53 weeks.   

The OTJ guide (point 41 to 44, and 81 to 90), and Apprenticeship Funding Rules (2023-2024 points 73 to 74), base the minimum OTJ calculation on the number of weeks as opposed to days.
 
The calculation is as follow: (X weeks (minus statutory leave) x Y hours) x 0.2.
 
Example:
Apprentice has a practical period start date of 01/08/2023 with a practical period end date of 02/08/2024.
This is 52 weeks and 4 days rounded to 53 weeks.
 
The calculation would follow as:
•    53 weeks minus the 5.6 weeks of statutory leave is 47.4.
•    47.4 weeks x 30 hours is 1,422
•    1,422 x 0.2 = 284.4 OTJ hours
This is rounded to 284 hours.

Regarding FRM37s, until the ESFA confirm they will accept an unrounded calculation, the only available option is to increase the planned hours recorded in your ILR and the respective compliance documents (Training Plan and App Agreement).  

The helpdesk also said "We appreciate your feedback and this will be passed onto the relevant teams for review." . I believe my query with the helpdesk continues to be open. 

(Edited)

Connor Goulding

Thank you for the update - not the answer I wanted but the answer I expected.

I have also raised a similar concern with the helpdesk but will make a start on resolving any issues highlighted in FRM37. Others have raised concerns over the accuracy of this monitoring report on JISC, so I expect them to make similar enquiries. Who knows, maybe we'll be listened to.. or maybe they'll just strengthen the rules with a clarification!

Melanie Aspinall

Paul Blackshaw - if you hear anything further from the ESFA, can you update this thread as clearly there are more providers that are going to be impacted by this. Thanks

Paul Blackshaw

Yes, I will gladly update this thread if anything else transpires. I genuinely hope the ESFA will acknowledge that rounding in the calculation is inappropriate and incorrect. 🤞 

Ruth Canham-James

I think that rounding guidance only appeared in Oct 2023, it wasn't in a copy of version 4 I have. We can't possibly be expected to apply a new calculation to anyone who started before that? Before that, we were following the published guidance which didn't mention rounding. Essentially for a full timer, that was =((((Planned End Date-Start Date+1)/7)/52)*46.4)*6 (replace 6 with what calculation you'd normally do for a part timer). All of our new FRM37 "errors" are just fine if we use that calculation.

Also, the equivalent pDSAT report to FRM37 isn't throwing up any of these records, so must be using a different calculation.

I think it's important we all report that we were using the published guidance available at the start date for anyone starting pre Oct 2023. We can apply this new rounded version of the calculations from the date the guidance was issued, but I'd still argue that, since this version was issued after the start of the academic year and there are no change notes explaining this, we shouldn't be expected to have noticed this.

Paul Blackshaw

Hi Ruth. I totally agree. The retrospective application is unreasonable; the inclusion of rounding is unnecessary and the calculation of 20% is mathematically incorrect. I strongly encourage providers to raise this with their ESFA account managers for the issue to be escalated within the ESFA. Ultimately, the introduction of the calculator and the rounding methodology needs to be retracted.

We cannot be expected to allocate resources to revise training plans, apprenticeship agreements and ILR records to accommodate this whimsical change.       

Melanie Aspinall

Ruth Canham-James - we found the same thing and we're applying the same logic. It's unfair and harsh to do this retrospectively.

Ruth Canham-James

Paul Blackshaw Yes, I agree that the rounding is wholly unnecessary in the first place, but I wouldn't have a problem if they introduced it for next year, and actually issued some change notes so we had a chance of spotting this new guidance.

I'm planning on not resolving any rows where the start date was before October 2023 when this guidance was issued, and noting that we were following the published calculation guidance as it stood when they enrolled. I'm still going to ask ESFA to retract this for 23/24 as a whole, and properly announce and introduce it for 24/25 if they really are attached to doing it.

Paul Blackshaw

Today's ESFA Update:

2. Information: R06 release of FRM37 data in the post-16 monitoring reports dashboard

We have now published the FRM37 report (called ‘Apprenticeship off-the-job training (OTJT) hours below the minimum’) in the post-16 monitoring reports dashboard.

We developed this report in tandem with the recently published Off-the-job training calculator to ensure providers have consistent data on apprentices who do not meet the minimum number of off the job training hours required to be eligible for government funding. 

The off-the-job training policy remains key to apprenticeship delivery, and we are committed to ensuring that each apprentice receives the right amount of off-the-job training that they need and are entitled to.

You must use these tools to ensure all apprentices receive the correct amount of OTJT for their programme. If this data appears inaccurate, we may require you to take further action to ensure you meet the minimum requirement. If individuals do not need the minimum required OTJT hours, they are ineligible for funding.

Martin Locock

So we "must use these tools" and the calculator uses rounded weeks.   

Jessica De Melo

I thought use of the calculator was optional, we introduced just before Christmas but now have a large group of learners who started before that point in the FRM37 report. Will also contact the helpdesk.

Jordan Banks

I have also raised this with the ESFA help-desk asking to confirm the other rounding rules.  The guidance states statutory leave should not be rounded, but on the calculator it is (but only in the final formula).  The calculator also rounds working hours per week to the nearest whole number but I cannot see that in the guidance either.

The rounding of statutory holiday does result in minimum hour calculation discrepancies for programmes where sometimes the guidance will be higher than the calculator, and sometimes not (i.e. programmes of length 382 to 388 days, 424 to 430 days, 480 to 486 days - it gets worse after 580 days). 

[Edit - changed "working hours" to "working hours per week" in first paragraph]

(Edited)

Richard Phipps

As Ruth said (we work together), we are challenging this.

Posting to add that also the Apprenticeship Rules for 23/24 still state a calculation without rounding:

73.3. Therefore, for a full-time apprentice following a 12 month apprenticeship, off-the-job training is delivered over 46.4 weeks (52 weeks minus 5.6 weeks of statutory leave). This provides, as a minimum, 278 hours of offthe-job training (46.4 weeks x 6 hours).

 

(It’s 276 or 282 if the hours were rounded down or up)

Paul Blackshaw

I received an email on 23/2/24 from Helpdesk@manage-apprenticeships.service.go.uk confirming they are speaking to their Specialist Support Team about this. 

Ruth Canham-James

Paul Blackshaw I've had similar from the regular ESFA helpdesk. 

Peter Hancock

Hi Ruth Canham-James,

Picking up your comment about the discrepancy between PDSAT and FRM37.....

Our PDSAT report 24A-215 Planned OTJT Hours was blank last month, but now it has 3 records, all of which were present in our ILR since before Christmas.  So, I think that the report methodology may have changed in the last month, and I have written to the PDSAT helpdesk to find out.  

Our latest FRM37 report includes the three shown on 24A-215, with many others as well (which have not finished, so they must be listed due to planned OTJT hrs?).
So, not only could both reports be wrong, but they may be wrong in a different way.   Surely they should both match?

(Edited)

Connor Goulding

Hi all,

I've just had the response from the helpdesk below.. pretty much invalidating the measure on the AAF dashboard in my opinion..

 

Good afternoon

Please see update below:

All your learner's must meet the eligibility of the 20% off the job training for an apprenticeship learner: -Apprenticeship funding rules 2023 to 2024 (publishing.service.gov.uk) ( Page 41 -especially 73.1). Please note these rules have been in place since 2017.
Off-the-job training (OTJT) Calculator and FRM 37 Report 
 
We have provided an OTJT calculator to help providers check compliance with the policy. To keep this as simple as possible, the start point (duration in weeks and the end point (minimum number of OTJT hours) are rounded to a full number. Statutory leave is not rounded.  
 
You do not need to use this calculator if you have your own. However, you must be satisfied that your calculation is in line with the funding rules. Note that if you are not using rounding, you may get a different result to the GOV.UK calculator; these learners may appear on the FRM 37 report and monitored as one of the indicators in the Apprenticeship Accountability Framework. If you are satisfied that the OTJT policy is being met, you don’t need to make any changes to these learners’ planned hours. 

Kind regards

 

Jordan Banks

I got the exact same response and drew the same conclusion.

It's disappointing to see that second paragraph, especially in a blanket email - it would take 20 seconds to look at the formulas on the OTJ calculator and realise that it doesn't do what they say it does (it rounds weekly hours, overall duration in weeks, and statutory leave).

Paul Blackshaw

Thanks for sharing your response from the helpdesk.

On reflection, I am pleased that funding rule 73 is recognised as being the defining criteria of the 20% requirement, and not the published calculator or OTJ guide. But with that being the case, I find it bizarre that a mathematically incorrect calculation is being used for compliance monitoring purposes. So come on ESFA, please correct your calculator so your monitoring reports are accurate and credible. Surely that's not too much to ask?

Paul Blackshaw

The current version of the published calculator rounds down as well as up, which means it calculates less than 20% for durations rounded down, as shown in this example.

 

Ruth Canham-James

I had the same reply. I do plan to adjust our calculations to match the ESFA ones from now on, as I don't want that many non-errors appearing on our FRM reports. I won't be updating existing ones.

I wouldn't be concerned about these appearing on the PDSATs (though we have nothing on report 24A-215, as that uses a different calculation from the FRM reports, which is absurd), as those only really get checked externally at audit, and based on this email we've had, we can justify our numbers.

The issue with these being on the FRM report, is that these are monitored by ESFA, and they love to email our principals off the back of those telling them we've done something wrong. I can annotate the report, but it makes it trickier to spot the genuine errors where we accidentally didn't follow the rules. That's why I'll be using the ESFA calculation in future, so eventually we can get back to FRM37 being only what we believe to be errors.

And yes, the new calculation absolutely is rounding statutory leave, which they explicitly say not to do. I wonder if using the new calculator, will push any "correct" ones into PDSATs as too low because it can round down.

Paul Blackshaw

I've still not received a reply from the helpdesk, other than the regular automated updates saying "we are working on your issue". The point I originally made back in December 2023, along with the calculation being mathematically incorrect, is that the rounded calculation is not compliant with Funding Rule 73.4. which states: ‘This formula must be adapted proportionally for longer duration apprenticeships’. In a mathematical context, this means having a constant ratio to another quantity, which unfortunately the rounded calculator does not provide.

Peter Hancock

I have read this week's ESFA Update which includes some notes about OTJT at para 3.  
ESFA Update further education: 6 March 2024 - GOV.UK (www.gov.uk)

Does this change anything?  

My reading of the information presented this week is that nothing has changed.  Although it states that this information is in response to several queries received at the help portal, it seems to only restate what was already published.  And, there is no comment about all the queries we have made about the calculation methodology (wrt rounding, etc...) and the FRM37 report.  

(Edited)

Ruth Canham-James

Peter Hancock Read the other thread about this. It changes things in that we've been told it's ok to have rows on that report as long as we're sure they're right.

Paul Blackshaw

Finally received a reply from the Specialist Support Team justifying the rounding of weeks used in the published OTJ calculator.

"The Specialist Support team have been in touch today to let us know that with regards to the OTJ calculation, the example that we have used in the funding rules for a number of years clearly has rounding in it (we use 52 weeks instead of 52.14 for a 365 day year) and we round 278.4 hours down to 278 hours. This has been replicated in the OTJT calculator and in the FRM 37 report."

So it looks like we are stuck with a mathematically incorrect calculation of 20% informing the FRM37 report. Unbelievable!!