Ruth Canham-James

Insufficient Funds at R14


I think this one is an interesting puzzle!

Apprentice is with a levy employer, who has occasionally had insufficient funds to pay the monthly payments. At R13, we knew they were completed, and had attempted their EPA, but we didn't yet have a result. We now have confirmed a fail, and they're not going to attempt again, and the "achievement" date was in July. We're now due the Completion 20% in 21/22. We can't know until we get the month end reports from R14 whether the employer had sufficient funds or not for that completion element.

Could we lose the 20% completion, because the employer had insufficient funds for the final completion element, that we couldn't know about until we got the co-investment reports for R14 too late? We wouldn't have recorded sufficient PMR. I think we're best to ask the employer to check the finances section of their DAS account to see if they think they have enough money. If not, do we guesstimate roughly what we think we'd need to invoice to then record a PMR (if they do actually pay) that would hopefully cover the 5% of the shortfall? If it turns out they had enough levy funds after all, we can just refund.

I was thinking this was all hypothetical, until I did some checking and we have one in exactly this scenario.


No one has replied to this post.

Steve Hewitt


69. To earn the completion element, you must have collected and recorded at 
least the amount of co-investment required for the whole programme up to the month 
before the completion payment is due, not counting any co-investment which might 
be required for the completion element itself. This gives some flexibility for levy 
paying employers whose apprentices have gone into co-investment in the final 

Apprenticeship technical funding guide (

Ruth Canham-James

Thank you! I'm going to have to see what happens. The money was technically "due" in July, but would only appear in R14. If it turns out they owed us £2.57, I won't have anywhere to record that as PMR even if we do invoice the employer for it, as I don't want to push the enrolment into 22/23 just for that. If we've been paid the completion anyway, what would be the point of pushing it to 22/23.

Jessica De Melo

Hi Ruth

We're in a similar position but our apprentice completed learning early so ESFA withheld 2 on-programme months until we were able to record achievement that occurred last week of July. These were finally highlighted as requiring co-investment on our R13 reports so we have issued an invoice to the employer but given the timing it's not going to show as collected in 21/22. I have now been told that means we won't receive the completion payment at all but I'm not sure how we are supposed to anticipate co-investment for levy payers....!!

Ruth Canham-James

Jessica De Melo Ouch! That's a really unfortunate set of events. If you can get the PMR in before R14 closes, you might get the payment? You won't know for sure until R14 is closed though.

Early completion can be a real problem for levy payers who have very little levy money. They might be able to afford the payments each month just about, but if you sting them with 3 month balancing payment, they can fall into insufficient funds. It's a good reason to try not to give overlong durations, but some will always finish early, however realistic the planned duration.

ESFA will likely tell you that the employers should be checking their financial info in the DAS, but I don't think many employers do that. We can't see it, so if the employer doesn't understand it, we don't stand much of a chance of anticipating co-investment.

Andrew Dickens

Ruth Canham-James Jessica De Melo  This is extremely frustrating.  I'm going to check this with the helpdesk too.  We have a few learner (5) that we had missed coinvestments for because they are levy, that at various points in recent months, didn't have enough funds.  The PMRs have now been updated but funning an R14 this morning, the indicative funding is still showing it wasn't collected "in year". 


Surely they cannot penalise us as a result of an oversight if we've got it in before hard close?



Ruth Canham-James

Andrew Dickens If your apprentices are continuing into 22/23, even just their achievement date falling into 22/23, you'll be fine. As long as you collect it by the end, it won't withhold the completion.

Also, don't worry about the PMR not showing in the Co-investment report, that report has so many problems! If you're very confident all the required co-investment has been recorded in PMR rows that you're returning in your 21/22 ILR, ESFA do know not to withhold payments. Their internal systems cope in a way the report cannot. We've got several examples of having received completion payments despite the co-investment report saying we hadn't collected the employer contribution. It's often when PMR is received in Aug/Sep for apprentices closed in the previous year. 

Andrew Dickens

Jessica De Melo 

We have learners who achieved in 21/22 but the co-investment not received until after the end of 21/22.  I raised this with the ESFA and got the following response:


Good afternoon, Andy.


Thank you for contacting the ESFA Service Centre.

The co-investment payment needs to be recorded using a date in the 21/22 year, i.e., 1st August 2021 to 31st July 2022 but prior to the achievement date in order to be picked up.

The PMR1 amount should be rounded up to the next whole pound.

Note the apprenticeship evidence file that the co-investment was received late, and the date amended.

Record and re-submit for R14.

Jessica De Melo

Andrew Dickens

Interesting as we weren't told about co-investment by ESFA until after the achievement date so that makes it almost impossible! Are they suggesting we record PMR payment in the same funding year but record internally (evidence pack) the true payment date if after July 31st? My instinct is surely not but I'm not sure how else to interpret this.

Andrew Dickens

Jessica De Melo   That is exactly how interpret that response. 

Therefore if for example a learner a learner achieved on 31st July, in the system you would record the achievement as 31/7/22 but record that the PMR was received on any date prior to that.  Then in your evidence pack you keep the evidence that it was actually paid on 1st September or whenever along with a note saying the date was amended in the ILR. 

It makes sense, but screams at every rule that they have.....  


Ruth Canham-James Martin West any thoughts on this?

Ruth Canham-James

Andrew Dickens I'd want it crystal clear in writing from ESFA that they intend for you to ignore this ILR rule (and the many mentions in the PSM);

  • The date for a payment record (AFinType = PMR) must be the date on which the cash payment was received from the employer.

I cannot find a real life example of a student with an achievement date in on academic year, with a PMR also in that academic year, but with a date of the following Aug/Sep.

The Service desk may well be wrong, they don't understand the intricate workings of the calculations, so it may be that PMR records recorded with a date of Aug/Sep, but reported in 21/22, will be counted. If they're right though, that urgently needs to be added to the guidance as an exception. We shouldn't be left guessing when and when not to obey the rules!


Jessica De Melo

Ruth Canham-James Andrew Dickens

I contacted the helpdesk to explain how unfair our scenario was i.e. how can we record payment before the 31st July if we didn't know the co-investment existed until September. Here is the response:

Without the co-investment being collected and recorded, the system will not release the completion element. I realise this must be frustrating, however co-investment can be triggered at any time, including at R13.

We have no control over it, the system will pick it up and include it on your funding reports. R13 and R14 gives providers the opportunity to action points like this to ensure their data is accurate before hard close.

I think in this instance we'll have to accept the loss and review our PED to see if we can avoid balancing payments and levy co-investment due near funding year end.

Ruth Canham-James

Jessica De Melo We shouldn't have to plan our delivery around ESFA reporting limitations! Do try adding PMR records in 21/22 with Aug/Sep dates, and see what happens. I'd be really interested to know if the completion element gets released.

I was once given special dispensation to put a fake Actual End Date in to release due funds. It was an early completion, who then didn't sit the EPA. Of course we deserved all the on programme payments, but the withdrawal meant we wouldn't have got all the due on programme payments. We were allowed to put the Actual End Date as the Planned End Date. In your case, I'd ask for special dispensation to just record the PMR with a date before it really was received, since it's an ESFA systems failure causing this.

Andrew Dickens

Ruth Canham-James Jessica De Melo


I now have it in writing from them that i should enter a PMR payment date prior to the completion date  (despite this being collected in September) and keep the evidence in the learner file of the actual receipt along with a note saying why it is different.....

Ruth Canham-James

Andrew Dickens Perfect! That's good to know. That really needs to be in the guidance. There will be so many providers who just won't have realised that payment logged in Aug/Sep but relating to a previous year, could be a problem.

Annabel Redshaw


We have some levy employers that have a shortfall on their levy payments, now I've got the R12 monthly payment report through I can have a look at total co-investment due from employer and invoice them.

I did this last month for 3 learners that we hadn't received completion payment for and I still can't see it showing on the monthly payment report in the month they achieved, should i be able to?




Andrew Dickens

Hi Anni, 


you need to check the monies released from previous period on the R12 summary and also have a look at the co-investment report, as that report will tell you the coinvestment required, paid And achievement funds generated and paid. 


Hope this helps 


Steve Hewitt

It won't be in the month they achieved, it will be in the month it was paid (ie this month)