Clair Ayling

Advice to trigger FRM37 when RPL does not reduce duration

Created

I have just received this advice for recording reduced hours on the ILR where the RPL does not result in a reduction in duration.   My understanding was that we record the hours being delivered as long as we were reducing the price and reporting the reduction in hours in the Apprenticeship Service.  Should I be triggering FRM37 in this scenario?

I can now confirm that we have received clarification about recording Recognised Prior Learning (RPL). The Specialist team have advised the following information:
 

·         The actual amount of funded off-the-job training hours must be recorded in the ILR.  Unfunded hours i.e those that do not need to be delivered because the assessment of prior learning has identified that the learner already has the knowledge skills or behaviours must be discounted in the figure recorded in the ILR.

·         You will trigger a FRM37 warning in this circumstance as there will not be enough off-the-job training hours hours in the ILR for the planned duration you are using. This is likely due to delivering a cohort and not being able to compress the duration for individual learners.  This FRM37 warning does not have immediate funding implications.

·         The hours that you have removed from the training programme must be recorded in the Apprenticeship Service for reduction of off-the-job training hours in the RPL screens.

·         You may choose for the learner to attend this unfunded training, on an unfunded basis e.g. if you wish them to complete learning as part of a cohort.

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Steve Hewitt

Wait, didn't they take all of this out of V1 of the rules? Was there in the draft but didn't make V1?

Clair Ayling

I can't seem to find it in either set of rules. Surely, this would mean any recognised RPL would trigger FRM37? 

Clair Ayling

And thinking it would be contrary to this rule:

28.1.2 If the provider cannot reduce the duration, they must still meet the minimum requirements of the off-the-job training policy for the full duration of the apprenticeship that has been reported to us in the ILR.

Steve Hewitt

RPL would only trigger FRM37 if it dropped them under 6 hours a week, so in a situation where you *were* reducing duration it wouldn't flag. But yes, your second point is why this is particularly weird...

Paul Blackshaw

I submitted pretty much the same query over 5 weeks ago and it's apparently sat with the Specialist Support Team. Will be interesting to see if I receive the same reply.  

Clair Ayling

I would be interested to know too. My original query was in January an I received the reply in June. I have asked for further clarification. 

Paul Blackshaw

I received a reply last week to the query I raised regarding how to adhere to the apprenticeship funding rules requirement to reduce the OTJT hours due to RPL on occasions when the delivery model is a fixed duration cohort. Here is the reply I received:

This matter was escalated to Specialist Support and their advice is as follows "The comments received indicated a set duration programme (for cohort groups with fixed start and end dates), that cannot easily be adjusted for learners with RPL, may appear (via the ILR and subsequent FRM37 report) to show that not enough OTJT hours are being reported to meet the minimum policy threshold. Until the FRM37 report can access and include data from the AS, learners may appear on this report. We are aware of the issue and will look to provide clarification to the sector as soon as possible."

Steve Hewitt

I don't understand how AS data will help? The whole point with this kind of learner is there's just a weird hole in the middle of their programme, right? And we don't report that when we're submitting to AS, do we?

Paul Blackshaw

I believe the AS currently captures whether or not the duration of the apprenticeship has been reduced due to recognition of prior learning, so I think the intension is for FRM37 queries to be referenced to this to presumably remove any queries automatically where the duration has not been reduced. So while it doesn't answer my question directly, there's recognition that clarification is needed and I suspect the rules will be retrospectively updated at some point in the future.  

Clair Ayling

Can I just also mention, after reviewing the AAFD specification, that that if this approach resulted in more that 20 learners being on on FRM 37 then organisations will be considered "at risk" with over 15 at "needs improvement"...

Steve Hewitt

I mean, 15 with big holes in the middle of their programme sounds like a lot, but also, that rather (as USUAL with AAFD) depends on your volume of starts (ie, if you're an HE provider with 20 cohorts, it might not be a lot...). Shame AAFD isn't "the start of the conversation" we'd all been led to think it was, although them terminating a University would probably have more repercussions than a small ITP...

(Edited)