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Your interpretation of the current and 21/22 rules may not be correct as it is up to the employer to select the EPAO.
The current rules are:
New standards must have an EPAO in principle in place before public funding can be accessed for new apprentices.
P177 At least 3 months before the apprentice reaches the gateway the employer must have:
P177.1 selected an organisation from the Register of End-Point Assessment Organisations (RoEPAO) to deliver the end-point assessment,
P177.2 negotiated a price with the end-point assessment organisation. Only those organisations listed on the RoEPAO will be eligible to be funded.
For 21/22:
P157 - New rule: To reflect that dialogue with the end-point assessment organisation must commence at least 6 months before the planned end date of the apprenticeship.
P159 - New rule: To reflect that the employer must both select and negotiate the price with the EPAO at least 6 months before the apprentice reaches the gateway.
HTH
Martin West - Hi Martin can I just check how you would handle the TNP on the ILR when an employer changes EPAO and this results in a reduced cost for EPA? I am assuming if you agreed for example a TNP1 of £4000 and a TNP 2 of £500 that you then can't add a TNP 3 of £4200 and a TNP 4 of £300 as you have not incurred any more training costs than originally planned?
You should only be using a residual price for example when there is a change of employer as the new price reflects the cost of the remaining amount of the programme to be delivered. You should follow the following guidance from the PSM.
Changes in negotiated price during the programme.
If a new price for training and/or assessment is negotiated at any point during the apprenticeship programme, then this must be recorded in a new price record (AFinType = TNP). You must record the date that the new price applies from in the AFinDate field.
If the previous price record for the programme was a total price (code 1 or 2), then the new price should also be a total price (code 1 or 2), unless the employer has changed. If the previous price was a residual price (code 3 or 4), then the new price must also be a residual price (code 3 of 4).
In your example for a reduced EPA price
TNP 1 01/08/2020 £4000
TNP 2 01/08/2020 £500
You would only need to add:
TNP2 01/06/2021 £300
As you say it would not be ethical to increase the training price when the EPA cost has been reduced.
HTH
Joanne Bell
Employer wants to change EPAO
Created