Claire Ford

frequency of recording levy payers' co-investment receipts

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We have some levy payers who have insufficient funds in their levy accounts and have to pay co-investment. I'm sure I've seen something which indicates how often we need to collect it, but can't find it. For efficiency, we would prefer to invoice and receive payments as infrequently as possible. Can anyone point me in the direction of specific guidance please?

Thanks

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Ben James

There's not really a prescribed timetable for collecting it, other than the requirement for you to have collected the 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.

There's a bit in the technical funding guide which infers you ought to collect it regularly (below) or else they'll withhold your OPPs, but in practice I don't think this actually happens:

71. If you have not recorded the necessary co-investment payments on the ILR we may withhold your monthly instalments until you have received these payments and you have recorded them on the ILR. For more information about recording coinvestment, refer to the Funding Rules. 

It's whatever works best for you, really. 

Ruth Canham-James

As Ben says, there's no official guidance. We do it quarterly, because the amounts can be so tiny, it just annoys everyone to invoice them for £3 each month. We always have 20+ apprentices every quarter who fall into this category, and they can be really tricky to find! I thought I could filter in the Apps Monthly Payment Report each quarter for any row where an employer contribution was required in the last 3 months, and was flagged as levy. However, I just found three employers that insist they're levy, so we'd recorded in our own systems as levy, and hadn't charged the 5% up front. In the Apps Monthly Payment Report they're listed as non-levy. The employers are going away to talk to the Apprenticeship Service about why that is.

If we can clearly see after 3-6 months that they never have anything in their levy pot, we invoice the whole 5% up front. If they ever do have any funds that we draw down, we refund. The Apps Contributions report is good for that, you can filter for anyone who's totally completed but the employer contribution is above 100% (don't refund until they withdraw or you've had the completion payment, they can end up in insufficient funds for the completion payment itself).

If you were short on PMR when you entered the Achievement Date, and you completion payment got withheld as a result, I think it would release if you then collect the remaining PMR later, as long as it's in the same academic year. We do extra checks and push hard for outstanding payments at R12 and R13 to make sure we don't lose any funding.

Claire Ford

Thanks Ben and Ruth. We're currently working on the basis of checking for additional invoices on a monthly basis but only invoicing quarterly, but the cat was put amongst the pigeons by someone suggesting we should be invoicing monthly. As you say Ruth, sometimes the monthly amount can be tiny and the cost of raising the invoice can outweigh it. 

Ruth Canham-James

I proposed it quarterly, everyone just agreed! I send all the info to our Finance and Business Development teams. Business Development contact the employers (they have an email template from me, and the underlying data should the employer want it), then they give Finance the go ahead to invoice, It's been working really well for the last couple of years, and the employers virtually always pay without argument. 

I did have one recently get very confused because they can see they do have funds, and I had to explain that those funds were going to their earliest starts, and when they finish, the funds will start going to the next in line.

Insufficient funds has to be one of the most complicated and time consuming parts of apprenticeship funding, and there's no guidance at all, you just have to work it out and do your best with reports that don't contain all the info you need.