Completion Status/ Payment processing

Here's the thing: What if they fail? If they come back to resit, your completion date isn't going to be right and then you'll have to update it and it all gets super messy.

So, unless you are certain that, pass or fail, that's them done, I'd advise against.

I'm not that close to all the different EPA processes but, I guess, if you had a nod and a wink that they'd passed and it was all fine, then you're reducing the risk of adding that completion date in, but, again, that's up to each provider to determine how happy they feel about doing that.

Hi Rachel Thompson

IMO - In the context of Apprenticeship standards the name of the 'Achievement date' ILR field is misleading as it is used to report when the assessment period ends whether that is with or without completion or achievement - see provider support manual details

Provider Support Manual: 2023 to 2024 - Recording apprenticeship outcomes and completion (submit-learner-data.service.gov.uk)

Cliff Notes: When the EPA is completed but you are yet to receive the result you should update the Programme aim completion status to '2' and the outcome to '8' as well as completing the 'Achievement date' field with the date last of EPA activity.

This may or may not trigger a completion payment - as I am not sure if just the 'achievement date' is enough to trigger this or the ESFA wait until they have a definitive outcome either 1 or 3. Either way the EPA period has been completed so should be reported as such.

HTH

Phil

I'm with Steve Hewitt on this one; we leave the programme as 1/8 until the outcome of the EPA is known, at which point we either update it to 2/1 if passed or 2/3 if failed (with no intention to re-sit). Largely based on the fact that I'd argue you can't update the completion status until you know the outcome as the EPA activities might not actually be 'complete' (e.g., maybe they determine something was missed). 

Also, just to add on the subject of completion payment (notwithstanding co-investment being outstanding/DLOCKs etc.):

52. For apprentices on apprenticeship standards who complete their learning or EPA in the 2019 to 2020 funding year or later, the completion element is earned when you record an ‘Achievement date’ in the ILR and the ‘Completion status’ is recorded using code 2 (‘The learner has completed the learning activities leading to the learning aim’). You will earn this funding for the month of the ‘Achievement date’, even if this month is different to the ‘Learning planned end date’ or the ‘Learning actual end date’ of the programme. 

Apologies for my long reply, but I firmly believe the rules and guidance around this need to be clearer because I'm aware of varying interpretations. The situation is not helped by having an ILR data field called "Achievement Date" that, for apprenticeship standards, actually means "Completion Date". Also, it's not clear whether an apprentice who fails the second part of a three part EPA and therefore does not attempt the third part can be recorded as complete. 

I think we naturally think of completion in terms of whether the apprentice has completed the apprenticeship but I think the funding system actually requires us to consider this in terms of completing the named services in the contract agreed with the employer. If we think of it this way, I think the following points of guidance from the ILR Specification and the Provider Support Manual (PSM) are slightly less confusing: 

ILR Spec - Achievement Date: This field will be used to record the end of the apprenticeship standard. This date concludes the End point assessment period that has taken place on or after 1 August 2019. Once this date is returned the Completion status and associated Outcome must be updated accordingly.

PSM - Achievement Date: The programme aim must be updated with the Achievement date recorded as the date the end point assessment period for the programme was completed, whether the outcome was a success or a failure.

ILR Spec - Completion Status: For apprenticeship standards, the learning activities for the programme aim include both the training and end point assessment. Code 2 must only be used for the apprenticeship standard programme aim where both the training and end point assessment activities have been completed.

PSM - Completion Status: In order to be recorded as ‘Completed’ (Completion status code 2), both the training and end point assessment activities for the programme must be completed. An end point assessment that has resulted in a failed outcome can be classed as complete as long as the learner reaches the end of the end point assessment period, rather than withdrawing. If either of these have not been completed, then the programme aim cannot be recorded with Completion status code 2.

ILR Spec - Outcome: For apprenticeship standards, learners that end their learning on or after 1 August 2019, Code 8 ‘Learning activities are complete but the outcome is not yet known’ must be used at the end of learning and prior to the end point assessment period. Once the End point assessment has taken place this is then updated accordingly.

PSM - Outcome: When the end point assessment period for the apprenticeship standard is complete, the Outcome field must be updated accordingly. If the apprenticeship standard has resulted in a failure at the end point assessment, the Outcome on the programme aim must be recorded as code 3 ‘No achievement’. If the apprenticeship standard is successfully achieved following the end point assessment, the Outcome on the programme aim must be recorded as code 1 ‘Achieved’.

So according to the above:

• The Achievement date needs to be informed by the completion of the EPA 'period'.  
• The Completion Status needs to be informed by the completion of the EPA 'activities'.
• And the Outcome obviously needs to be informed by the outcome (achieved, no achievement or outcome not yet known).

In practice, I think (and hope) the intention is for providers to be able to claim and receive funding amounting to the total negotiated price where the delivery of the training is complete and the EPA period/activities are sufficiently complete to generate an overall outcome. Which only seems fair in view of the provider having incurred the costs of delivery and EPA at this stage. So regardless of whether the outcome is known, having delivered the services agreed with the employer and inevitably progressed the apprentice to a point that will determine a grade/outcome for the apprenticeship, it should (in my mind) always constitute a 'completion' and earn the provider the completion payment. 

So in answer to Rachel's original question, yes, I would record the achievement date as the day the learner sat the EPA.

OK, as you can imagine, I've been through all of this with ESFA/App Service...

Despite everything that we've ever used "completion" to mean, whatever it says in ILR guide or PSM, they were adamant that we do not set the compstat to 2 and add the value into achdate until we know the apprentice has definitely stopped.

Specifically, 2&8 should never be used for Apprenticeships because, they argue, until you know if the outcome is 1 or 3, you can't know that the compstat is definitely 2.

Paul:

Also, it's not clear whether an apprentice who fails the second part of a three part EPA and therefore does not attempt the third part can be recorded as complete. 

No, they can't, they're a withdrawal because they've not completed all elements of the EPA.

Hi all,

following this post I contacted the ESFA directly, you cannot set compstat to 2 or claim payment prior to the results being received. 

Steveh

No, they can't, they're a withdrawal because they've not completed all elements of the EPA.

Interesting. So that's based on whether all the elements of the EPA have been completed. Until recently, that's what I thought. But the PSM says it should be based on whether the learner reaches the end of the end point assessment period, and I can only think it refers to the period rather than the elements/activities because it recognises the period will naturally end when the learner can progress no further by virtue of either completing all elements or being unable to progress any further due to failing part way through.

So in the example of an apprentice failing the 2nd element of a three element EPA, I'm currently open to the possibility that this constitutes reaching the end of the EPA period and should be recorded as 2/3 complete but no-achievement. 

So in the example of an apprentice failing the 2nd element of a three element EPA, I'm currently open to the possibility that this constitutes reaching the end of the EPA period and should be recorded as 2/3 complete but no-achievement.

The EPA period is certainly 'over', but if they've opted to not undertake the 3rd of this 3 part EPA, they have (by definition) withdrawn. The EPA activities have not been completed and the operative extract from the guidance would be:

An end point assessment that has resulted in a failed outcome can be classed as complete as long as the learner reaches the end of the end point assessment period, rather than withdrawing.

I understand it might be somewhat of an argument of semantics, but there's overwhelming precedent to suggest this is what the ESFA believe to be the way the rules ought to be interpreted. Could they be clearer? Absolutely. 

Great to read peoples views and interpretations on these important matters.  

The Funding Rules define Completion Payment as “A payment we make to providers when an apprentice completes all their learning and undertakes the end-point assessment (the apprentice does not need to pass).” The reference to ‘undertake’ is critical here as it means to begin to do something, ie begin the EPA, which I think supports the view that recording 2/8 to trigger the completion payment is acceptable practice, especially as 2/8 does not generate any warnings or errors in the ILR rule violation report. And it also supports recording 2/3 for apprentices who fail without completing all elements of their EPA.

I think the policy intentions are relatively clear but the mechanism and associated guidance lacks the clarity we need to be certain when completion payments can be claimed. It would be incredibly useful if someone from the ESFA with absolute understanding of this would contribute. 

Discourse is definitely welcome. 

I do have to disagree though. The funding rules specifically say (concerning the completion payment):

120. We will pay the remaining balance (the completion payment) of the total negotiated price, up to the funding band maximum, to the provider when the apprentice has undertaken all the activity relevant to the apprenticeship, including completing all elements of the end-point assessment.  

As far as evidence of completion is concerned, the funding rules are also quite clear that it must include:

Signed statement by employer and provider that the apprentice is still employed until the end-point assessment is completed;

Evidence from the EPAO that the EPA has been attempted and either:

• Achieved and the certificate claimed (this could include a screenshot from the EPAO portal); or
• Failed (and no resit taken). 

Good points Ben.

So despite having incurred all the costs, satisfied the terms agreed with the employer and enabled the apprentice to complete the EPA to the point of obtaining a fail grade, if the apprentice has not completed "all elements of the EPA" there's no completion payment. Hmm. Well, it says what it says, but I'm struggling to believe that's the intention because it seems unreasonable. 

Not to be too cynical but regardless of what the intention is/was, it's certainly the policy...

Earlier this week I asked the Helpdesk to confirm whether an apprenticeship can be recorded as complete if the apprentice has sat and failed part of their EPA and therefore does not attempt any remaining parts of the EPA.  Two days later, here is their reply:

Dear Paul,
Ticket reference number: 1016532.
I can confirm that rule 120 refers to the end-point assessment being recorded with the outcome in the ILR. It refers to 'all elements of the end-point assessment' because the completion payment is not paid until the outcome is recorded. If the apprentice fails an element, they are not able to continue and therefore they have completed all the elements they could and receiving a fail outcome.
I hope that clarification is useful.

Always nice to hear from the service desk. I do maintain a slight disagreement though, particularly concerning the bit where they say

"if the apprentice fails an element, they are not able to continue and therefore have completed all elements they could"

This is just not necessarily true in all cases and is heavily dependent on the structure and scheduling of the EPA activities. In instances where they're either all held on the same day, all marked on the same day, or results are communicated at the same time, an apprentice wouldn't know if they've failed immediately, so couldn't say "I didn't do the 3rd element because I'd failed the 2nd". They'd be withdrawing themselves from the process before the failure had been determined.

In instances where they were told of the failure, and they are not physically allowed to continue, I could be convinced. Though if they want to re-sit/re-take, it introduces additional complications.

It raises a fair question though, and certainly would benefit from further clarification because with the greatest of respect to the service desk, there have been quite a few occasions where people have received conflicting advice concerning the same/similar queries. 

If you record a completion status 1 and outcome 8 with the actual end date in the ZPROG- programme aim, what do you record in the component learning aim, I seem to get rule violation errors processing the ZPROG and learning aim the same?

When the training is complete and the apprentice is confirmed as reaching the gateway, I record the programme aim as 1/8 and the component Z000 aim as 2/8. 

That sounds correct in the same way I have it and seems to be the only way it didn't create a rule violation error. Thank you for confirming.