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Created 14 October 2021 16:08
Hello all (especially anyone from the ESFA)
We're doing the final final checks on our ILR and I want to raise an issue regarding what to do with Study Programme learners that transfer to an Apprenticeship mid-way through their Study Programme. The funding guidance: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/934846/16_to_19_funding_guidance_Regulations_2020_to_2021-Version_1.2.pdf
The relevant part of the guidance: If a student is recorded as having successfully completed a study programme early and is then transferred onto an Apprenticeship programme at the same institution, the institution must make sure it is not drawing down two sources of ESFA funding for the same period of time.
DSAT report 21B-007 supports this rule. I understand the intent of the report would be to pick up significant numbers of learners that early complete a Study Programme, and then take up an Apprenticeship, therefore generating potentially full time 540+ Study Programme hours as well as a significant amount of Apprenticeship income.
The language in the guidance is not precise. There is a clear distinction between someone who completes a Study Programme and moves on to an Apprenticeship vs someone who transfers part way through a Study Programme on to an Apprenticeship. The 16-18 funding formula penalises an institution where a leaner transfers (i.e. Comp Status 3 and Withdraw Reason 41) using the retention factor which would reduce from 1 to 0.5 for a transferred Study Programme learner. This would reduce the funding for the Study Programme for the Provider on a lagged basis in their future allocation. If the provider then reduces the Study Programme hours , then there is a double hit, both a retention hit AND a reduction in Study Programme hours.
As an example, a learner that gets halfway through a full time Study Programme, transfers (not completes) to an unrelated Apprenticeship, would appear on PDSAT 21B-007, but I do not think it is correct to lower the hours or to adjust the TNP on the Apprenticeship, on the basis that the funding formula has already done the appropriate adjustment!
I am confident that this is what happens, but not so confident that an external auditor or even PMO would understand this nuance.
Can you reply to this message and clarify that the scenario above would NOT require and reduction to hours or TNP despite being on PDSAT 21B-007.
As an aside, where a learner transfers to an apprenticeship related to the Study Programme, I would expect a TNP discount (or Planned hours reduction) to allow for overlapping learning on the Study Programme.
No one has replied to this post.
(I assume you've also sent this to the Service Desk?)
I've only had one of these and it was Classroom Hairdressing to App Hairdressing, so I didn't really think about the monetary aspect of the transfer, just protecting our Ach rates...
15 October 2021 08:46
Hi Steve - would like to get something on here publicly that may help a wider group going through audit. Audit situations where there is no recourse to get a sensible answer from either the auditor or the ESFA are not much fun. Also it doesn't seem to be widely understood (often by auditors) that a DSAT report is not necessarily an error! It might be take-a-look-and-and-see-if-it-an-error packed up as an error.
My guess is that a provider somewhere had a model that delivered a small FM25 qual with potentially high hours, early completed whole cohorts and moved the on to an App. This seems to inadvertently hurt providers delivering proper FT Study programmes who aim to move those learners into Apprenticeships and jobs.
15 October 2021 10:56
You know you're preaching to the choir here ;)
15 October 2021 11:01
Here's the official answer on this. To quote the reply in the context of the example in the original post, it does "appear a little harsh", and is definitely not in "provider favour"!
Thank you for your enquiry.The starting point to the answer is Funding regulations paragraph 13 (d), 64 and 67. Paragraph 67 states: Students are usually only eligible for one ESFA funding model as the funding provided is intended to cover the whole of their learning programmes. We set out some additional advice in Funding regulations: Annex C in the Question and answer 15 to help make clear that under no circumstances should any student have planned hours recorded for any period in which the same funded institution is claiming Apprenticeship funding. This applies regardless as to circumstances of transfer and in all such cases the planned hours should be removed for any time in which the Apprenticeship funding is being claimed. The advice in Q&A 15 is merely intended to help make sure the requirements not to duplicate funding as set out in 13 (d), 64 and 67 can be as easily applied as possible by all providers. We will take your question into account in writing Funding regulations 2022 to 2023 but this does not change the advice above for you to make the required adjustments for 2021 to 2022. We are now setting out this advice to all questions on study programme to Apprentcieship funding Our advice makes the following points: The advice on adjusting planned hours applies to all 16-19 study programme students moving to Apprenticeship provision within same provider We accept for some students this may appear a little harsh but reducing planned hours reduces the value of “retention deduction”Many such students will have undertaken some under pinning knowledge for the Apprentcieship deliveryWe apply our guidance to make advice on adjusting funding data as simple as possible but accept some reductions are likely to be “in our favour” whereas others maybe in the “provider favour”We have been forced to adopt this guidance due to the numbers of students being put through 16-19 study programmes to reduce Apprenticeship costs We expect students started onto study programmes to be completed before moving onto Apprenticeships and we cannot afford to “incentivise by funding arrangements early completion/withdrawal from study programmes”No 16-19 students should ever be double funded at the same time at same provider and the simplest method is to reduce planned hours and not adjust Apprenticeship funding.I trust this answers your query but please reply to this email if you have any further questions. Please use our ESFA online form if you have any future queries.Many thanksESFA Customer Service
08 November 2021 08:57