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As (like most providers) it sounds as if you've defaulted your total negotiated price to the funding band maximum, this puts you in a bit of a tricky situation when things like this happen. You'll need to decide whether you want to
- reduce your training price (TNP1) to account for the increased EPA (which, if properly costed, will leave you out of pocket) or
- pass the cost of the increased EPA price onto the employer (which probably won't make them too happy)
As for the ILR, this will depend which option you're going for, and what year the learner started.
For starts before 01/08/2022 the ILR expects the full cost, including where it's over the funding band max;
P105.13 If the total negotiated price (TNP1 and TNP2) exceeds the maximum of the funding band, then the agreed total must be recorded on the ILR. The employer must pay in full the difference between the band maximum and the total negotiated price.
For starts on/after 01/08/2022 the ILR only wants to know what the price is up to the funding band max (and less any RPL);
P207.2 If the price you agree with the employer exceeds the maximum of the funding band, then you must agree off-line (outside of the ILR and apprenticeship service) how the employer will pay any difference. We do not need to know about the amount of this difference. You may charge VAT on the difference. This difference must not be funded from the apprenticeship service account or co-investment.
In either case, you're almost certainly going to have to add at least a new TNP2 as of the date of the new EPA cost was agreed. This guidance will help with the ILR changes - Provider Support Manual: 2022 to 2023 - How to record changes to the apprenticeship (submit-learner-data.service.gov.uk)
The EPA price should not change once agreed as it is subject to contract.
P164 It is the responsibility of the employer to select the end-point assessment organisation and negotiate the price within the funding band for assessment. You must contract with the end-point assessment organisation that has been selected by the employer and lead the relationship with them including where you subcontract the delivery of apprenticeship training. This allows you, on behalf of the employer, to make payment to them for conducting the end-point assessment. The written agreement must set out the arrangements for sharing relevant information about the apprentice so end-point assessment and certification can take place, including arrangements for any re-takes and payments. This must also include arrangements for a change of circumstances, which may delay, or lead to the cancellation of, the end-point assessment.
P207.5 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 (in TNP2) 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.
I expect many providers are entering standard EPA costs in the ILR before they have contracted with the EPAO on the employers behalf.
Tyron Wain
EPA Price Increase, now above the max band
Edited
Hi all.
We have had a price increase from our EPAO, and if we updated the new EPA price, combined with the training price it will now be above maximum funding band for that standard. I feel this issue might be more common with the whole economic situation.
Also we have had an employer who wishes to change EPAO, and the new EPAO prices are also above the existing one - and it also tips over the max funding band.
What is the best thing to do in these situations?