Paul Blackshaw
ILR, QAR and funding rules specialist with 13+ years experience. Providing ITPs and colleges with consultancy services to primarily support their Apprenticeship operations and management.
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Paul Blackshaw commented,
Knowingly reporting and flagging compliance queries which are actually compliant is outrageous and unacceptable. The issue causing the FRM37 queries needs to be fixed. This is not an unreasonable request or expectation and I had hoped it would be resolved by now. It seems this matter will need to be escalated.
Knowingly reporting and flagging compliance queries which are actually compliant is outrageous and unacceptable. The issue causing the FRM37 queries needs to be fixed. This is not an unreasonable r...
Paul Blackshaw commented,
Thanks for sharing your response from the helpdesk. On reflection, I am pleased that funding rule 73 is recognised as being the defining criteria of the 20% requirement, and not the published calculator or OTJ guide. But with that being the case, I find it bizarre that a mathematically incorrect calculation is being used for compliance monitoring purposes. So come on ESFA, please correct your calculator so your monitoring reports are accurate and credible. Surely that's not too much to ask?
Thanks for sharing your response from the helpdesk. On reflection, I am pleased that funding rule 73 is recognised as being the defining criteria of the 20% requirement, and not the published calcu...
Paul Blackshaw commented,
I first put the question to the helpdesk in December 2023 regarding the rounded calculation of 20% (first published by ESFA in October 2023) and it's retrospective application. Since then, I've received a message saying it has been referred for further investigation by the Specialist Support Team. Last update was received 23/2/24 confirming the investigation is ongoing.
I first put the question to the helpdesk in December 2023 regarding the rounded calculation of 20% (first published by ESFA in October 2023) and it's retrospective application. Since then, I've rec...
Paul Blackshaw commented,
Hi Ruth. I totally agree. The retrospective application is unreasonable; the inclusion of rounding is unnecessary and the calculation of 20% is mathematically incorrect. I strongly encourage providers to raise this with their ESFA account managers for the issue to be escalated within the ESFA. Ultimately, the introduction of the calculator and the rounding methodology needs to be retracted. We cannot be expected to allocate resources to revise training plans, apprenticeship agreements and ILR records to accommodate this whimsical change.
Hi Ruth. I totally agree. The retrospective application is unreasonable; the inclusion of rounding is unnecessary and the calculation of 20% is mathematically incorrect. I strongly encourage provid...
Paul Blackshaw commented,
Hi Kay. You will need to determine and agree with the apprentice and employer a new duration that will allow the apprentice to complete the remaining OTJT hours. So, for example, if they completed 200 OTJT hours prior to the BIL and the programme was planned to include 700 OTJT hours, then the apprentice will require a new duration with sufficient time complete the remaining 500 OTJT hours.
Hi Kay. You will need to determine and agree with the apprentice and employer a new duration that will allow the apprentice to complete the remaining OTJT hours. So, for example, if they completed ...
Paul Blackshaw commented,
When the training is complete and the apprentice is confirmed as reaching the gateway, I record the programme aim as 1/8 and the component Z000 aim as 2/8.
When the training is complete and the apprentice is confirmed as reaching the gateway, I record the programme aim as 1/8 and the component Z000 aim as 2/8.
Paul Blackshaw commented,
I'm experiencing exactly the same 😞 and also questioned my sanity 🙄
I'm experiencing exactly the same 😞 and also questioned my sanity 🙄
Paul Blackshaw commented,
I believe the AS currently captures whether or not the duration of the apprenticeship has been reduced due to recognition of prior learning, so I think the intension is for FRM37 queries to be referenced to this to presumably remove any queries automatically where the duration has not been reduced. So while it doesn't answer my question directly, there's recognition that clarification is needed and I suspect the rules will be retrospectively updated at some point in the future.
I believe the AS currently captures whether or not the duration of the apprenticeship has been reduced due to recognition of prior learning, so I think the intension is for FRM37 queries to be refe...
Paul Blackshaw commented,
Just to close off this thread, the matter was escalated and the outcome of the appeal confirmed my interpretation and application of the funding rules is correct. So just to confirm, the level of functional skill learning for apprentices undertaking level 2 apprenticeships must be informed by their prior attainment and not their initial assessment. As for the incorrect logic in the PDSAT (which I believe caused the error by the auditor), I've received a reply stating the logic remains correct and is not affected by the policy change. I've tried to escalate this but my request appears to have been ignored.
Just to close off this thread, the matter was escalated and the outcome of the appeal confirmed my interpretation and application of the funding rules is correct. So just to confirm, the level of f...
Paul Blackshaw commented,
I received a reply last week to the query I raised regarding how to adhere to the apprenticeship funding rules requirement to reduce the OTJT hours due to RPL on occasions when the delivery model is a fixed duration cohort. Here is the reply I received: This matter was escalated to Specialist Support and their advice is as follows "The comments received indicated a set duration programme (for cohort groups with fixed start and end dates), that cannot easily be adjusted for learners with RPL, may appear (via the ILR and subsequent FRM37 report) to show that not enough OTJT hours are being reported to meet the minimum policy threshold. Until the FRM37 report can access and include data from the AS, learners may appear on this report. We are aware of the issue and will look to provide clarification to the sector as soon as possible."
I received a reply last week to the query I raised regarding how to adhere to the apprenticeship funding rules requirement to reduce the OTJT hours due to RPL on occasions when the delivery model i...