Ruth Canham-James

AEB/ASF Changes 2024/25 Webinar FAQs

Created

I thought I'd create a thread for chat about this. I think most of us received an email titled "AEB/ASF Changes 2024/25 Webinar FAQs" on 14/06/2024. If you didn't, find a copy from somewhere.

This was a question I've had for two years, and had contradictory info on, so this is good to have in writing:

If a course is flagged as FCFJs course and a L3 legal entitlement course on FALA, which category would be prioritised under ASF? Should we assess under the legal entitlement first and then FCFJs? There is no priority order for assessing learners if they are eligible under both offers. The course will also attract the FCFJ uplift regardless of which offer it is categorised under.

When they say "The course will also attract the FCFJ uplift regardless of which offer it is categorised under", I believe that may only be true if you record the LDM code 378. Originally we were told that these could only be funded under legal entitlements, so we didn't code as 378, and we didn't get the uplift. Code 382 (FCFJ specifically for low wage) has been retired.

These two are just great news:

Does that mean that a learner can now access FCFJs funding more than once? Yes, that is correct. If a learner continues to earn below the earnings threshold then they will continue to have access to the FCFJ offer.

Can a learner aged 19-23 who does not have a full Level 2 qualification now be funded under local flex or do they still need to do a full Level 2 first? Learners aged 19-23, without a first full level 2, can now be fully funded under the local flex offer but only if they earn below the earnings threshold. If a 19-23, without a first full level 2, has a salary above the earnings threshold they will be co-funded for qualifications off the local flex offer, but will still be fully funded for qualifications off the legal entitlement list.

I am really concerned about the evidence requirements for these:

Assuming benefits do not count towards the ‘earnings threshold’ would this mean someone who is unemployed and in receipt of benefits could be fully funded for learning at Level 2 and below? Equally, someone unemployed but not in receipt of benefits and with zero earnings would therefore be below the ‘earnings threshold?’ Yes, on both accounts provided the relevant documentation is produced. For someone unemployed and not claiming benefits this could include bank statements showing outgoings and incomings.

Does a 19+ student who is unemployed but not claiming benefits meet the earning threshold criteria? We have a number of young adults who don’t work but don’t claim benefits because they live with parents who support them. How do they prove it? Yes, such an adult would be eligible, and appropriate evidence might be a provider noting they have seen a bank statement showing incomings and outgoings.

Aside from the fact that lots of people have multiple bank accounts and can just show you the one with low/no income, it just feels a huge invasion of privacy and a massive overstep for a provider to be trawling through bank statements. With Low Wage, we just asked for payslips usually, so didn't need to see bank statements. You expect to show all your bank statements when you take out a mortgage, not when you sign up for a course. Also, what has outgoings got to do with it?

Very interested to see whether the new definition of unemployed includes that the learner needs to be seeking work. If not, that includes lots of retirees, which seems an unusual group for ESFA to choose to fund.

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Darren Harlow

I'm surprised more people haven't contributed to this post seeing as how the 'clarification' version has just been released.

I couldn't agree more with the whole bank account scenario, it just 'feels' wrong on all levels. Steve H posted on CMIS that he has challenged some of these issues and again I agree totally that this should be self-declaration as the value of collected evidence, for the reasons you have stated, is never going to be robust. Also, we are not accountants; showing income against expenditure and our supporting calculations. Students could also have embarrassing things on their statements that they would be mortified should we see them - like a monthly direct debit for a Fleetwood Town season ticket for example :-)

It does appear that older members of society are supported to return to work by gaining qualifications. It would appear that retirement is not forever nowadays but let's watch this space after 4 July.

Darren.

Karen Simmons

V2 is definitely more than a "clarification" version, now includes parts that were not mentioned at all in v1 and appeared to have been removed from 23/24.  Cannot believe how late these changes are.   Checking bank statements is a no-no for us, it's not appropriate to ask staff to trawl through bank statements adding up income and outgoings - and won't prove anything.  

Darren Harlow

Well we are currently still on V1 with V2 to come later - in July, I'd expect it to be very early July too ;-)

Information: Updated adult skills fund funding rules for the academic year 2024 to 2025

The Education and Skills Funding Agency (ESFA) has updated the adult skills fund (ASF) funding rules guidance that was first published in March 2024, to clarify 2 points.

  1. When using the earnings threshold, you must apply this to the learner’s gross annual salary and exclude any benefits.

  2. You can fund unemployed learners using the ASF and we have added the unemployed definition back into the guidance.

In July, we will issue version 2 of the ASF funding rules 2024 to 2025 to include performance management rules.

Karen Simmons

Silly me I was thinking the update yesterday was v2 :-)  

Ruth Canham-James

Good to have another version out since the Webinar FAQs document.

There are some really great new avenues of funding for those not employed and not on benefits! Just as long as they're seeking work. I mentioned on CMIS that we'll have some form of self-declaration to confirm the bit about seeking work and the programme being relevant to their employment prospects.

For those of you that don't read the CMIS Jiscmail, there were a number of other concerns about checking bank statements raised:

  • Students without a bank account
  • Students with multiple bank accounts
  • Students with joint accounts where their partner earns above £25k
  • Not all money going into an account will be earnings, it could be support from a family member or any number of things

Plus as Darren points out, transactions that they may not want us to see (or bank transfers from friends with what seemed like hilarious notes)! If we ask only to see the monthly/yearly summaries, that doesn't account for partner salary and/or other income that's not earnings. If the money in is more than £25k, then we'd have to trawl through the detail to establish how much of it was earnings. How does the student prove that any salary income is their partner's and not theirs? It's just not possible. You can't prove absence of something.

Richard Heath

We have grave concerns about the need to view bank statements, for the same reasons that have already been posted here: it is both highly intrusive, and not remotely reliable. And frankly a July date for clarifying the unemployed definition is completely unhelpful. Why the delay?

Does anyone know if these concerns are being fed back to DfE?

Peter Hancock

On the issue of "proving" low wage, I believe the old adage about "can't prove a negative" applies.  
Like others, I think this should be self declaration from the learner.  

Peter Hancock

On the FCFJ processing priority, I am surprised that they say there is "no priority", as this will affect year-end funding reconciliations.  On the other hand, I think it gives providers the "flexibility" to choose which allocation is going to pay for the learning aim, so that's a good thing, right?