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So looks like we were right. We have have heard back from the DfE via our auditors who didn't seem to have the same interpretation of the wording for Earnings in ASF Funding Rules Glossary so the contacted the DfE. Below is the response they got from DfE:
"As pension payments are generally considered unearned income and are not received in return for current work undertaken, they would not fall within the ASF definition of earnings. The rules also refer to evidence of earnings being wage slips, employment contracts and gross annual wages, which further suggests that the threshold relates to employment or self-employment income only
Therefore, where a learner's income consists solely of a pension, this we would interpret this as not counting towards the ASF earnings threshold."
Julie Butler
Fee remission and Pension income
Created
Hi, just wanting to double check that 'pension' income is not included as earnings for fee remission on the basis the definition of earnngs is money received for work. Our Admissions department are querying as it is included for house income and bursary calculations.
Earnings
A measure of the money people receive in return for work done, before tax (gross). It includes salaries but not unearned income, benefits in kind or arrears of pay.
Kr
Julie