Helen Ogden

When to use the new Select learners from the ILR feature

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The new feature on the apprenticeships service that allows you to use your ILR data to avoid data mismatches seems like a sensible way forward. However, there is no clear guidance on when to do this in order to avoid delays in approval on the apprenticeships service account. In previous years we have worked with employers on the apprenticeships service records as we were also working on the ILR records, thus opening up communication between employer and provider.  I've copied the guidance below for information. Our issue is that according to the ILR rules we need to wait 42 days.  However that will leave us having to import a lot of apprentices onto the service after the 42 day window. To do it sooner we would need to include learners in the ILR before 42 days which risks compliance issues if anyone withdraws before (because they should be a non starter and never have gone into the ILR). We want to use this new feature but can see some problems with it. I just wondered what other providers are doing?

"Selecting learners from ILR

When you submit ILR data to Submit Learner Data, an apprentice record will be created for you to select when adding an apprentice. The employer will still need to approve apprentice details. 

Submitting your ILR data as early as possible, during the ILR Guaranteed Collection period, allows time for the employer to approve the records.  

New apprentices are available in your provider account within 15 minutes of submitting your ILR data to Submit Learner Data. 

Apprentice records can be created and submitted for employer approval in your provider account at any time."   

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Ruth Canham-James

Why are you waiting 42 days? ILR guidance says you should include all learners who have done even one instance of learning. They still have to go in the ILR if they withdraw between days 1 and 42. I think most providers just record their apprentices in the ILR as soon as they start. Sometimes it turns out they never actually started and we have to remove from the ILR, and sometimes that leads to some clawback. I know we're not supposed to return things that didn't actually happen, but when you've got 10k+ students, that's a serious challenge to keep track of. It always gets corrected pretty quickly.

I've raised this issue with DfE. We should be allowed to record apprentices in our ILR a little before they start to allow for this function in the DAS, but we can't because of an ILR error about financial records dated after the file creation.

Helen Ogden

Hi Ruth thanks for your reply. That's interesting to hear that you don't wait 42 days. We have always tried to abide by the 42 day rule to avoid non-starters becoming early withdrawals and ending up on our PDSAT reports. Technically we prefer to accurately record them as non starters in our system when we can.  In our system we have to QA verify before they go into the ILR so we tend to pick up non starters fairly quickly, although some do inevitably slip through. So their data is there but we don't do the final approval before 42 days to move them into the ILR xml file. If we were to submit and later remove them surely we'd get an FRM06 because they would disappear from the ILR? However, I've thought of a potential solution for us which would be that we do QA all learners who are due into the ILR as soon as the submissions window is open (e.g. for R04) and I do an early submission (as soon after R03 is closed as possible). That  means that the data will be available on the apps service and our administrator can them use the automated process. We then have about a 3 week window to check for any non-starters who I should be able to exclude from the ILR before R04 hard close. So those should in theory never go into the final ILR and the problem will be solved. I didn't think about the submission window being open for about 3 weeks when I posted yesterday. I was just thinking would it  mean our administrator had to QA a large batch of learners rather than doing what she does now which is cohort by cohort.  We will give it a go and see what happens as I like the idea in principle and it should have the benefit of eliminating DLocks which will definitely be a large time saving and mean that data is accurate on both systems. 

Helen Ogden

I meant to say also Ruth I totally agree with you on the issue of being able to include learners earlier. We have very few who drop out early anyway, and as you say funding can be clawed back for those few.  We are going to discuss this internally today so thanks for your feedback

Ruth Canham-James

FRM06 only applies across ILR years, not across two returns in one year. It's pretty common practice to submit students in one ILR, and then just remove them from the next when it turns out they actually never started. Each ILR within a year pretty much overwrites the last one. There are exceptions for specific returns like R06, R10, where they use the data for other things like allocations, so it's more important to get those as accurate as possible, but I don't think that's the case for apprenticeships.

Phil Dawe

'42 day rule' is not a thing for inclusion into the ILR. As Ruth says all learners with at least one instance of learning should be included. The 42 days is used by the DFE to ascertain if the learner passed the qualifying period.

The PDSAT for early withdrawals is an information only report it does not imply that there is anything wrong with the enrolments just that they did not pass the qualification period. I would not worry that there are learners on there, if they were in fact early withdrawers.

 

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