Ruth Canham-James

LDM codes 378 and 391

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I'd like a second opinion on this issue. The 24/25 ASF Funding Guidance says:

You must:

  • use LDM code 378 and FFI code 1 to claim for funding for 19 to 23 year olds learners, who have not achieved a full level 3 and earn above the earnings threshold
  • use LDM code 378, FFI code 1, and LDM code 391 when recording learners who meet the earnings threshold criteria or are unemployed, or are 19 to 23 years old and have not achieved a full level 3

We've always created a sort of artificial hierarchy of reasons for full funding. Obviously 16-18 first, then we'd go for FFL2/3, then benefits. As I read the above, any student who is eligible for full funding under either FFL3 OR unemployed/below earnings threshold, must be flagged as both 378 and 391. It's only the 19-23 year olds waived as FFL3 on a FCFJ aim, that earn above £25k that should have 378 and not 391. Since the earnings is not an ILR field, we don't record that (unless we fully fund for that reason). So if a student was fully funded on the basis of FFL3, I actually wouldn't know from our data whether they were also below earning threshold.

Practically speaking, what 19-23 year old studying a Full Level 3 aim is going to be earning £25k+? It seems rather unlikely.

I just wanted to raise it to see if anyone else had noticed this, and whether people agree with my interpretation. I've set up something now so we will be recording whether each adult is earning above/below £25k. It might end up being useful at some point for funding optimisation. We already know employment status, benefit status, whether they're looking for work, and prior attainment from ILR values. Earnings is the only thing missing so we're basically completing the set.

Also, another thing we noticed is that the ILR Spec describes LDM 391 as just Below Earnings Threshold, but the ASF rules include Unemployed in that. I assume that's because they originally rolled those things into one, and only later separated Earnings Threshold and Unemployed into distinct categories in the ASF rules.

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Steve Hewitt

To answer the last bit, I think we have to think of Unemployed as a subset of below Earnings Threshold (in that they must have an income of <£25k) now?

I'd argue it's a bit weird to ask everyone/store data for everyone if you're not going to use it, but wouldn't argue it particularly strongly? Depends on the number of 19-23s in yr Adult cohort I think?

Ruth Canham-James

Steve Hewitt Yes, we're thinking of it that way (that's how it was in the original 24/25 ASF rules), but it's still confusing now they've split it.

If they're an adult on a fundable course, we'd ask them all their relevant personal circumstances anyway so we can then determine fundability. Many of them fill in paper forms and send in, then we get back to them on whether they need to pay or not based on their answers. We won't be asking adults on courses that aren't ASF fundable anyway, like HE/Apps/L4+ courses.

Alastair Gilbert

The other scenario I'm unclear about is a 19-23 year old eligible for FF because they don't have a full L3, who is unemployed and not looking for work, and not on benefits. From my reading of this in the unemployed definition:

  • not receiving any benefits, wants to be employed, and you are satisfied identified learning is directly relevant to their employment prospects and the local labour market needs. In order to claim full funding for learners who are unemployed and not in receipt of benefits, you must indicate that they earn below the earnings threshold by using LDM code 391 and FFI code 1

They wouldn't meet the unemployed definition. They don't meet the new earnings threshold definition, because they're not employed or self-employed. In this case, I'm not clear that we should be using LDM 391.

Ruth Canham-James

Good thought. If they are not looking for work, so don't meet the definition of unemployed, I wouldn't use 391.

Steve Hewitt

Isn't there a derived variable in the validation rules that flags them as first FL3 based on age and prior attain, and therefore doesn't require them to have anything else to be FFI 1?

Peter Hancock

I know I'm reopening an old thread, but it is still relevant in 25/26.  

Is this saying that when a 19-23 year old without a full L3 wants to do a 1st full L3 that happens to be FCFJ fundable that it must be funded from FCFJ (LDM378) and cannot be funded from ASF core funding?  

Steve Hewitt

Cripes!

SO, the 24/25 funding calc didn't work properly ANYWAY and put all the 19-23s in the ASF line *regardless* of how you coded them.

This has been fixed in 25/26 so if you put 378 in, it'll be FCFJ (and generate the extra £150/£600) and if you don't, it'll be ASF. I think we get to choose, but happy to be corrected?