Rule violation LearnDelFamType_124

Thanks Simon.  This is disgraceful.  They should have made that clear back in December.

Surely a critical point we need to flag to the ESFA here is that they are completely ignoring devolved authority rules with this error at the moment. That is just unacceptable as more and more providers are working with devolved contracts. We do not have time to add (and possibly later have to remove again) DAM codes to thousands of records that are coded correctly according to the published devolved authority rules.

From what I can see, it looks like none of the validation rules for learners on Funding Model 38 (Adult Skills) contain exclusions for learners on active benefits. Whereas previous years when it was Funding Model 35 the description of the equivalent rules clearly included an exclusion for this. See https://guidance.submit-learner-data.service.gov.uk/24-25/ilr/appendices for a link to the most recent version of the validation rules. 

I don't know if that is intentional or an omission, but I lean towards intention at this point. It is pretty clear to see why learners simply "unemployed & on benefits" with no LDM/DAM codes applied are erroring, based on what the description of the validation rule states.

All learners FM38 aged 24+ doing a learning aim level 2 or below with FFI1 will error with this unless they have the earnings threshold added or meet one of the listed exclusions:

RoTL (LearningDeliveryFAM.LearnDelFAMType = LDM and LearningDeliveryFAM.LearnDelFAMCode = 328),

Restarts (LearningDeliveryFAM.LearnDelFAMType = RES),

English and maths basic skills (LARS_BasicSkillsType = 01, 11, 13, 20, 23, 24, 29, 31, 02, 12, 14, 19, 21, 25, 30, 32, 33, 34, 35 (where LearningDelivery.LearnAimRef = LARS_LearnAimRef and LearningDelivery.LearnStartDate => LARS_EffectiveFrom (and =< LARS_EffectiveTo or LARS_EffectiveTo = null)),

Full Funding for learners in devolved areas  (LearningDeliveryFAM.LearnDelFAMType = DAM and LearningDeliveryFAM.LearnDelFAMCode = 023),

Essential Digital Skill (LARS_BasicSkillsType = 43 (where LearningDelivery.LearnAimRef = LARS_LearnAimRef and LearningDelivery.LearnStartDate => LARS_EffectiveFrom (and =< LARS_EffectiveTo or LARS_EffectiveTo = null))

Digital Functional Skills (LARS_BasicSkillsType = 44 (where LearningDelivery.LearnAimRef = LARS_LearnAimRef and LearningDelivery.LearnStartDate => LARS_EffectiveFrom (and =< LARS_EffectiveTo or LARS_EffectiveTo = null))

I notice that Submit Learner Data known issues says that this issue is now fixed, however we still have rule violations affecting thousands of learners. Is everybody resorting to entering LDM 391 as a fix? In my understanding, a learner cannot meet the definition of unemployed unless they earn below the earnings threshold, anyway.