Paul Blackshaw commented, 29 January 2024 09:57

Great to read peoples views and interpretations on these important matters.   The Funding Rules define Completion Payment as “A payment we make to providers when an apprentice completes all their learning and undertakes the end-point assessment (the apprentice does not need to pass).” The reference to ‘undertake’ is critical here as it means to begin to do something, ie begin the EPA, which I think supports the view that recording 2/8 to trigger the completion payment is acceptable practice, especially as 2/8 does not generate any warnings or errors in the ILR rule violation report. And it also supports recording 2/3 for apprentices who fail without completing all elements of their EPA. I think the policy intentions are relatively clear but the mechanism and associated guidance lacks the clarity we need to be certain when completion payments can be claimed. It would be incredibly useful if someone from the ESFA with absolute understanding of this would contribute. 

1. Completion Status/ Payment processing

Great to read peoples views and interpretations on these important matters.   The Funding Rules define Completion Payment as “A payment we make to providers when an apprentice completes all their l...

Paul Blackshaw commented, 26 January 2024 16:58

Steveh No, they can't, they're a withdrawal because they've not completed all elements of the EPA. Interesting. So that's based on whether all the elements of the EPA have been completed. Until recently, that's what I thought. But the PSM says it should be based on whether the learner reaches the end of the end point assessment period, and I can only think it refers to the period rather than the elements/activities because it recognises the period will naturally end when the learner can progress no further by virtue of either completing all elements or being unable to progress any further due to failing part way through. So in the example of an apprentice failing the 2nd element of a three element EPA, I'm currently open to the possibility that this constitutes reaching the end of the EPA period and should be recorded as 2/3 complete but no-achievement. 

1. Completion Status/ Payment processing

Steveh No, they can't, they're a withdrawal because they've not completed all elements of the EPA. Interesting. So that's based on whether all the elements of the EPA have been completed. Until r...

Paul Blackshaw commented, 26 January 2024 14:49

Apologies for my long reply, but I firmly believe the rules and guidance around this need to be clearer because I'm aware of varying interpretations. The situation is not helped by having an ILR data field called "Achievement Date" that, for apprenticeship standards, actually means "Completion Date". Also, it's not clear whether an apprentice who fails the second part of a three part EPA and therefore does not attempt the third part can be recorded as complete.  I think we naturally think of completion in terms of whether the apprentice has completed the apprenticeship but I think the funding system actually requires us to consider this in terms of completing the named services in the contract agreed with the employer. If we think of it this way, I think the following points of guidance from the ILR Specification and the Provider Support Manual (PSM) are slightly less confusing:  ILR Spec - Achievement Date: This field will be used to record the end of the apprenticeship standard. This date concludes the End point assessment period that has taken place on or after 1 August 2019. Once this date is returned the Completion status and associated Outcome must be updated accordingly. PSM - Achievement Date: The programme aim must be updated with the Achievement date recorded as the date the end point assessment period for the programme was completed, whether the outcome was a success or a failure. ILR Spec - Completion Status: For apprenticeship standards, the learning activities for the programme aim include both the training and end point assessment. Code 2 must only be used for the apprenticeship standard programme aim where both the training and end point assessment activities have been completed. PSM - Completion Status: In order to be recorded as ‘Completed’ (Completion status code 2), both the training and end point assessment activities for the programme must be completed. An end point assessment that has resulted in a failed outcome can be classed as complete as long as the learner reaches the end of the end point assessment period, rather than withdrawing. If either of these have not been completed, then the programme aim cannot be recorded with Completion status code 2. ILR Spec - Outcome: For apprenticeship standards, learners that end their learning on or after 1 August 2019, Code 8 ‘Learning activities are complete but the outcome is not yet known’ must be used at the end of learning and prior to the end point assessment period. Once the End point assessment has taken place this is then updated accordingly. PSM - Outcome: When the end point assessment period for the apprenticeship standard is complete, the Outcome field must be updated accordingly. If the apprenticeship standard has resulted in a failure at the end point assessment, the Outcome on the programme aim must be recorded as code 3 ‘No achievement’. If the apprenticeship standard is successfully achieved following the end point assessment, the Outcome on the programme aim must be recorded as code 1 ‘Achieved’. So according to the above: The Achievement date needs to be informed by the completion of the EPA 'period'.   The Completion Status needs to be informed by the completion of the EPA 'activities'. And the Outcome obviously needs to be informed by the outcome (achieved, no achievement or outcome not yet known). In practice, I think (and hope) the intention is for providers to be able to claim and receive funding amounting to the total negotiated price where the delivery of the training is complete and the EPA period/activities are sufficiently complete to generate an overall outcome. Which only seems fair in view of the provider having incurred the costs of delivery and EPA at this stage. So regardless of whether the outcome is known, having delivered the services agreed with the employer and inevitably progressed the apprentice to a point that will determine a grade/outcome for the apprenticeship, it should (in my mind) always constitute a 'completion' and earn the provider the completion payment.  So in answer to Rachel's original question, yes, I would record the achievement date as the day the learner sat the EPA.

1. Completion Status/ Payment processing

Apologies for my long reply, but I firmly believe the rules and guidance around this need to be clearer because I'm aware of varying interpretations. The situation is not helped by having an ILR da...

Paul Blackshaw commented, 26 January 2024 12:59

Because of the short period of unemployment, you might need a new ACT entry wef 10/7/23 to match the TNP 3&4 entries of the same date. As to why you received funding for July, August and September, that's a mystery, unless the records in DAS were not updated until October, in which case the records prior to October continued to match your ILR and therefore allowed the claim for funding.  

1. DLock 10

Because of the short period of unemployment, you might need a new ACT entry wef 10/7/23 to match the TNP 3&4 entries of the same date. As to why you received funding for July, August and September,...

Paul Blackshaw commented, 26 January 2024 12:48

If this relates to the details to be recorded in the Apprenticeship Service, it is referred to as: "the total off-the-job training time for the apprenticeship standard before any reductions, in whole hours". I believe this needs to be the total OTJT hours in the provider's training plan for their delivery of the 'full' programme (to an apprentice without any RPL).    https://www.gov.uk/government/publications/apprenticeships-recognition-of-prior-learning/apprenticeships-initial-assessment-to-recognise-prior-learning       

1. Total OTJ training time for Apprenticeship Standard

If this relates to the details to be recorded in the Apprenticeship Service, it is referred to as: "the total off-the-job training time for the apprenticeship standard before any reductions, in who...

Paul Blackshaw commented, 26 January 2024 11:53

Ok, so you've determined that 21% of the training hours are not required due to RPL. Funding Rule 29.2. provides a worked example to explain how you must "Reduce the total price by at least 50% of the prior learning percentage, from the funding band maximum (the 50% reduction recognises that there are some fixed costs in the apprenticeship)." Therefore, a price reduction of at least 10.5% is required, so your calculated cost reduction of 54% will be considered compliant. But please do be aware that the funding available for you to claim will be limited to the remaining balance of the funding band maximum less the funding claimed for this programme by the previous provider, so I recommend you discuss and agree with the employer how any potential shortfall will be charged and paid.  

1. Transfer Learners

Ok, so you've determined that 21% of the training hours are not required due to RPL. Funding Rule 29.2. provides a worked example to explain how you must "Reduce the total price by at least 50% of ...

Paul Blackshaw commented, 24 January 2024 17:16

Thanks Steve. Sending it to the Service Desk was the procedure a few years back. We asked early in December what to do, but are still without a reply. Like you, I'm hoping ESFA staff will reply. 

1. Change of senior management personnel

Thanks Steve. Sending it to the Service Desk was the procedure a few years back. We asked early in December what to do, but are still without a reply. Like you, I'm hoping ESFA staff will reply. 

Paul Blackshaw commented, 24 January 2024 16:03

Hi Claire. Don't enter the original start date, but do include the restart indicator. Original start date is only collected if the learner is restarting the learning aim at the same provider, for example if they are returning from an agreed break in learning. Your assessment of RPL needs to determine the content of training and OTJT hours required to complete the programme. The difference between this and what you would usually deliver to an apprentice without any RPL (and therefore needing your 'full' programme of training) is the RPL hours reduction.

1. Transfer Learners

Hi Claire. Don't enter the original start date, but do include the restart indicator. Original start date is only collected if the learner is restarting the learning aim at the same provider, for e...