FRM37 Reports - Apprenticeship Accountability Framework

I put together this for my managers in case we do get flagged as "At Risk" for this, so they have all the info in one place:

The latest AAF documentation has just been published: https://www.gov.uk/government/publications/apprenticeship-training-provider-accountability-framework/apprenticeship-training-provider-accountability-framework-and-specification--2

The area of particular note for me is this:

We have lots of records on the FRM37 report, but they all started before ESFA changed the OTJ calculations used in FRM37 and added some rounding. Each month, I monitor those, and I separate them out on the report with this note:

These were not flagging as errors before the 24/25 R05 report (Dec), because they met the old ESFA minimum OTJ calculation. After this, ESFA changed their minimum OTJ calculation advice but applied it retrospectively for this report. It has been confirmed by ESFA that we can continue to use the old calculation from the funding rules, even with newer enrolments. The discrepancy is just due to changes in rounding. We are now using the newer calculation for new apprentices, which is why the most recent start on this report is May 2024, so any new rows on this report, with a start after 22/05/2024, will need investigating.

This is the conversation I had about this with ESFA, and they have confirmed that it’s fine to have rows on FRM37 if we’re confident we followed the guidance. We definitely did and can evidence that if required.

Hi Ruth

Whilst I still do not have clarification on why the PDSAT and FRM 37 calculation does not match, I have been told that it is supposed to and there will be an article update soon. I have however been given the following guidance:

• Rounding issues: The FRM37 report uses the same “rounding” logic as the OTJT calculator (published on gov.uk in October 2023). However, from Service Desk queries, it appears that Providers have developed their own calculators over time which do not have this rounding. As such they are getting a slightly different outcome (between 1-3 hours) between their version of a calculator and ours.

• After FRM37 was released, in response to rounding queries we produced an Update article that clearly stated that the calculator was created to help providers and that they didn’t need to use our version. We were also clear that providers did not need to make any changes to learner’s planned hours if they were satisfied that the OTJT policy was being met.
• Whilst FRM37 queries are an assurance measure within the Apprenticeship Accountability Framework (AAF) (i.e. that apprentices are receiving sufficient substantial training), the AAF team have been involved in all OTJT/FRM 37 conversations and communications to providers will be revised as appropriate.

• If they are using a different calculator and a duration in days (rather than weeks) than they may well be getting a different result. The gov.uk calculator rounds the days to the nearest number of weeks (e.g. 52 weeks for 365 days rather than 52.14 weeks); it also rounds the “answer” (the minimum requirement) (e.g. 278 hours rather than 278.4 for a 52 week programme).  It doesn’t round statutory leave as that’s set elsewhere e.g. statutory leave is 28 days or 5.6 weeks - that’s not a DfE policy so we can’t really choose to round that).

• We have since issued an update article to say that 1-3 hours is not material and will not impact compliance, provided they are assured themselves that they have abided by the policy (e.g. if they are using a calculator that works on days rather than weeks, or one that doesn’t round up/down, that’s fine - that’s all they need to explain to anyone who asks (e.g. if they are audited, have an AAF discussion).

I hope this helps, if you do have any further queries then please get back to me and I will do my best to get further clarification.

Apologies again that this has taken so long.

Kind regards

Laura

Customer Service 19+ ILR
Customer Service Division
Digital Data Technology Directorate 

Here is the ESFA Update where they also confirmed it was ok to use our own calculator. It says: “Note that if you are not using rounding, you may get a different result to the GOV.UK calculator; these learners may appear on the Funding Rules Monitoring (FRM) 37 report and monitored as one of the indicators in the apprenticeship accountability framework. If you are satisfied that the off-the-job training policy is being met, you don’t need to make any changes to the learners’ planned hours”.

If we are flagged as “At Risk” because of these, we need to push back on that, as they’ve clearly said it’s fine.

Ruth Canham-James - this is fantastic - thank you so much!