Updating EPA Price

From the Technical guidance.

197. If the apprentice changes employer, the provider and new employer should agree a price for the remaining training and assessment, we call this a ‘residual’ price. You should record this residual price in the ILR using the 'Apprenticeship Financial Record' entity in ILR returns. You record a residual training price as TNP 3 and a residual end point assessment price as TNP 4. These identify the price of the remaining training and/or assessment (including end-point assessment for apprenticeship standards) to be delivered following this change in circumstance to an ongoing programme. We will use this price information to calculate the earnings for the remainder of the programme and match to the new employer's account if they have one.
     198. In the example below, a training price (TNP1) of £3,500 and an end point assessment price (TNP2) of £500 is negotiated on 1 September 2018 at the start of an apprenticeship in the 2018 to 2019 ILR. On 23 November 2019 the employer changes, so a residual training price (TNP3) is negotiated at £2,000, and a residual end point assessment price (TNP4) is negotiated at £500.

1. In your ILR for the original funding year, you would record your negotiated prices as follows:

1. In your ILR for the following funding year, when you have negotiated the residual price, you would record your negotiated prices as follows:

HTH

Hi Martin

Thank you for your quick reply, that is correct and what we have been recording.  The problem happens when we then go into another contract year and the EPA price changes when the learner goes to sit their EPA.  Example below,

Same scenario as above the learner then sits EPA on the 23/11/20 and the EPA price has increased to £600.

TNP   3      23/11/20     1900

TNP   4      23/11/20      600

This will result in an overclaim and going over the funding band maximum

If we reduce the TNP3 and TNP4 to take into account the funding we have received from Nov 19 to Nov 20 and enter this new reduced negotiated price then this will result in a datalock error?

You only use TNP3 and TNP4 when a learner changes employer, otherwise it's just new TNP 1 and 2.

Hi Steve

You can't add a TNP1 and TNP2 after your have entered a TNP3 and TNP4 the system does not allow it, the ESFA have confirmed it is TNP3 and TNP4 to update the EPA price if the learner has previously changed employers but it results in a datalock or an overclaim.

Oh I see, sorry, missed that the learner had changed employer.

If the EPA has gone up, then, yes, you will go over the top of the band, that's a feature, not a bug (a pretty rubbish feature, but that's how it's meant to work). You're meant to charge the employer the difference.

If it's gone down, then you need the employer to change the price to match on AS and then it won't datalock.

But what if you have not charged the maximum price band to start with, you don't just go over the band it is then an overclaim as the system will automatically pay you up to the maximum band.  Also what employer is then going to pay the EPA price increase when you have already negotiated a price 3 years previous at the start of the apprenticeship.  Some of the employers are not paying anything if they are 16-18 SME and then we are supposed to turn around and say sorry you have to pay the EPA price increase because if you do not then we do not get paid the 20% achievement payment, what employer in their right mind would pay that?

If the employer changes the price then doesn't this change the price from the start of the record as the AS system does not allow you to add a second price and date for the same employer, so then it will still data lock as we can't change the price to match on our system from the original change date if we have gone into a different contract year?

Your contract with the EPAO should indicate if it is a fixed price or subject to increase.

If the EPA costs are subject to change the employer should be advised of this and it should be included in your contract with the employer.

It can be an issue where you include the total price at the Cap at the start of the programme, but the funding rules includes the following:

P159 At least 6 months before the apprentice reaches the gateway the employer must have:

P159.1 selected an organisation from the Register of End-Point Assessment Organisations (RoEPAO) to deliver the end-point assessment,

P159.2 negotiated a price with the end-point assessment organisation. Only those organisations listed on the RoEPAO will be eligible to be funded.

P228.2 You must accurately reflect the negotiated prices for training and end-point assessment onto the ILR. Where you and the employer do not know the details of the end-point assessment organisation at the start of the apprenticeship, you must enter the price for end-point assessment once this has been confirmed. This field in the ILR must be left blank until the price of the end-point assessment has been confirmed to ensure accuracy.

You can revise the price at a later date, and this will be reflected in the AS but I expect some providers just take a hit on this where they have set the total cost at the CAP.

Hi Clair

I have had ongoing conversation with the ESFA and the latest reply last week was that there is no definitive answer, they gave 3 options that we could do but each option came with different problems and not one option was the correct answer.  I have sent a reply asking that as the ESFA can not give us a definitive answer on how to update the ILR in this scenario then am I within my rights not to update the TNP 3 and 4 as this will not result in an overclaim.  I await a reply.

Thanks

Tracey

Thanks Tracey. Sorry you still haven't had a definitive answer. I can't think of any way of resolving and we updated one learner's record following audit advice and now have the same overclaim scenario. Did the ESFA suggest repaying overclaim via EAS or any other mechanism? 

Hi Clair

There wasn't an overclaim for us so we did not have to repay any monies.

Hello there

I have had a similar issue with updating a change in EPA price where a learner has changed employer previously, in an academic year that is closed. In our case to avoid a data lock we entered the TNP3 and TNP4 values in resulting in a overclaim of funding. I was wondering have you had feedback from the ESFA since in how to record this correctly. I have a ticket open, and I know what the issue is but no way of knowing how to fix this and what to do in the future to record this correctly. The issue is also what dates to use and what to do with the employer account?  Can anyone help please?

Hi Desiree

This was the reply I received and they were unable to give me a definite answer and did not reply to my further email regarding not updating the EPA price in the ILR and DAS but ensuring we have the paperwork signed by the employer to show the correct price as this would  result in no overclaim.

Reply from ESFA

The issue arises when there are TNP3 and TNP4 records involved.

Consider the following.

TNP3

Date : 10^th May 2023

Price : £2000

TNP4

Date : 10^th May 2023

Price : £500

So here this is declaring that the remaining cost as of 10^th May 2023 is £2,500 made up of £2000 training costs and £500 assessment cost.

If 4 months down the line in September 2023 for example, we need to adjust those costs then we can do this as there is no apprenticeship service to worry about.

Let’s say there were on programme earnings of £100 for May, June, July and August for example totalling £400 then the remaining cost in September would be £2,100.

This could be recorded as

TNP1

Date : 18^th September 2023

Price : £1,700

TNP2

Date : 18^th September 2023

Price : £400.

So here we are declaring that the remaining cost as of 18^th September 2023 is £2,100 made up of £1,700 training costs and £400 assessment cost.

We have adjusted the cost of the EPA (reduced £500 to £400). We have also considered the earnings between May and September.

So, without the apprenticeship service it’s straight forward.

The problem arises when the apprenticeship is funded through the AS. There will be an employer’s record with a start date in May 2023 with an agreed cost of £2,500.

As soon as the second set of TNP’s are recorded with a date of September this will trigger a DLOCK_07 as the £2,100 cost does not match the £2,500 on the employer’s record.

So, what are the options.

Option 1

The first option which is probably the neatest option data wise would be to stop the employers record with the cost of £2,500 with a stop date of September 2023 meaning the last payment is August 2023.

Create a new record on the AS which would be for that same employer with a start date of September 2023 (to line up with the new TNP3 and TNP4) with the reduced cost of £2,100. The new TNP’s would then match to the new AS record.

The downside of this is that there is additional work for the employer and provider to do this. Non levy employers would have to use another reservation to do this as the change of employer functionality cannot be used as it does not allow a change of employer back to the same employer.

Option 2

The second option would be to let the DLOCK_07 price mismatch trigger against that first employer record with the cost of £2,500. This could be triaged and passed to the employer to approve the cost reduction from £2,500 to £2,100.

Although this isn’t strictly true and may look a bit wrong and appear the wrong thing to do – behind the scenes the cost on the employer’s apprenticeship service record is only there to ensure that the cost the provider is claiming in their ILR matches what the employer has agreed to. The cost on the employer’s record doesn’t service any other purpose. All of the providers earnings and therefore payments are driven from the ILR.

Option 3

The third option which would only work if the provider were claiming the funding band maximum but would mean less work for the employer and provider in terms of creating new AS records or approving price changes etc would be to ignore those £400 earnings from May to September and record the following TNP records for September.

TNP3

Date : 18^th September 2023

Price : £2,100

TNP4

Date : 18^th September 2023

Price : £400

So, they’re adjusting the EPA from £500 to £400 as they need to, but they’re effectively saying the price remaining in September 2023 (£2,500) is the same as the price that was remaining back in May 2023 (£2,500).

We know this is wrong as there are £400 of earnings between those dates - but as the September £2,500 still matches to the employers record it does avoid the DLOCK_07 issue.

The indicative earnings report would inform them that they are attempting to claim £400 over the funding band maximum and they would only be able to earn the £2,100.

As you can see – not ideal and not one straight forward answer to this problem.

Hi Tracey

Thank you for your response. I thought that once you use a TNP3 and TNP4 in the ILR you can't use TNP1 and TNP2 entries again? I appreciate what you have send through and will try and think about the best solution. Can I ask if there is a limit on the AS ACCOUNT how far back (IN MONTHS) you can go back and stop and employer account and start a new one with residual costs, is there flexibility with this?  If none of these options has a good outcome, can you reverse an entry in the ILR, or correct it e.g. option 3 once it has been uploaded to the ESFA? 

Hi Desiree

You are correct, you can't use a TNP 1 and 2 after you have used a TNP 3 and 4 or you will get an error.  This was their response, not what I agreed with!

You can go back and make a stop as far back as you want on the AS account but you will only be able to start a new one the month before the current month you are in as it will be like making a new reservation, unless they are Levy then you can go back to any month.  

You can reverse the entry in the ILR as long as it it is this current contract year, you will not be able to make any amendments to 23-24 or before as they are now closed.

We have still not resolved how to record changes in EPA prices for learners who have changed employers as we are not willing to risk the changes on the DAS where the employer does not approve the funding because it would wipe out all of our funding for the learners.

Thank you, Tracey, I appreciate your feedback.