Gill Knight

FRM37 Planned/Actual off the job hours


I have 9 learners appeared on the FRM37 report suggesting that either the planned or the actual off the job hours are below the minimum. The PDSAT reports 24A-215 and 24A-216, which identify those potentially not meeting the minimum requirements, are empty. Any suggestions? I cannot see there are any known issues with FRM37 being reported.


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Paul Blackshaw

Hi Gill. please see Further education and training providers community - OTJT hours calculator

Gill Knight

Oh my ... rounding up ... rounding down ... as if it wasn't complicated enough.

Thanks Paul, I will check them out.


Gill Knight there were reports on CMIS yesterday that FRM37 is returning far too many learners? And, not a known issue exactly, but it has only just been switched on for 23/24, so maaaaaaybe it's not quite right...

Darren O'Neill

Steveh Hi Steve, we have had a significant number of learners drop onto our FRM37 report at R06. As far as we can see, the new basic ESFA OTJ calculator was published in October 2023, along with version 5 of the Apprenticeship OTJ training policy, which seems to mention rounding up or down for the first time (no mention in version 4).

Our thoughts are that we will only remediate the learners who started from October 2023 onwards, as there was no guidance from the ESFA around rounding figures before this time. What are your thought on this?


Darren O'Neill right now I'm in the interesting position of not looking after any Apps, so I've not seen what it's producing, yesterday's reports didn't *sound* like it was just rounding errors, let me talk to someone and get back to you.

Ruth Canham-James

It's not strictly an error, but they're applying a new calculation retrospectively to students who started before the new new calculation was published, which is obviously a problem. See the thread that Paul linked to above.

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.


Gill Knight

Thanks Paul

I have now requested a list of the learners they think are below the minimum as I cannot locate any and there is no function to drill down on this report.

Paul Blackshaw

ULNs for the individual FRM queries are available by clicking View All Data.



Gill Knight

Thanks Paul. When I checked the other day it was empty but they are showing now. Still don't actually make sense though.

6 of them started in 2022 and 1 of them is on a BIL

Peter Hancock

FRM37 seems to have a dual purpose, showing learners who meet one or both of the following conditions:
a) PLANNED OTJT hours are insufficient
b) ACTUAL OTJT hours are insufficient.  

Unfortunately the report does not say which of the conditions has triggered the learner to be included on the report.  
Considering that the ILR specification says the ACTUAL OTJT hours should be returned only "at the end of the practical period or where the apprentice leaves the apprenticeship early", is it correct to assume the following about learners on the FRM37 report:

1) If the apprenticeship has not ended (ie actual end date is null), their inclusion on the report must have been triggered only by the PLANNED OTJT hours.  
2) If the apprenticeship has ended (ie the actual end date is not null), their inclusion on the report could have been triggered by either or both of the PLANNED and ACTUAL OTJT hours.  

Would be interested in your thoughts.  

Sarah Williamson

Hi All,

Please can I confirm that The expectation is to change all apps, even those who started in a  previous year?

Many Thanks,


Ruth Canham-James

Sarah Williamson I'd hold on for now, as a lot of us are querying this change. It's unreasonable to suddenly apply new calculations retrospectively.

Paul Blackshaw

I first put the question to the helpdesk in December 2023 regarding the rounded calculation of 20% (first published by ESFA in October 2023) and it's retrospective application. Since then, I've received a message saying it has been referred for further investigation by the Specialist Support Team.  Last update was received 23/2/24 confirming the investigation is ongoing.  

Peter Keating

I would be interested to know the outcome of this as we have had the majority of our provision appear on the FRM37 report of which most ot them start in previous Academic years and looks like its the rounding up of weeks causing the issue throwing alot of ours out by about 3 hours!

Ruth Canham-James

Peter Keating It was in the ESFA Update yesterday.

Basically, you don't have to use the rounded calculations as long as you're sure your calculations are correct according to the main guidance. As I understand it though, it won't stop us from getting flagged as "at risk" in the Apprenticeship Accountability Framework if we are not using their new rounded calculations. We will then have to have an ESFA "management conversation" to explain why we're not wrong.

Also, the equivalent PDSAT report is using a different calculation, presumably not rounded.


The PDSAT calculation counts the number of Sundays between start and end to work out the "weeks" because, well... who knows...

And yes, "you can do it how you want but we'll still flag them" is an... interesting way of approaching the subject...

Paul Blackshaw

Knowingly reporting and flagging compliance queries which are actually compliant is outrageous and unacceptable. The issue causing the FRM37 queries needs to be fixed. This is not an unreasonable request or expectation and I had hoped it would be resolved by now. It seems this matter will need to be escalated.