Jessica De Melo

On-Programme Clawback for Learner sitting EPA


Hi All

We have our first apprentice sitting EPA soon and we submitted the ILR in R09 to reflect this, using the PSM as our guide:

I think we've made a mistake somewhere though as on our payment reports for R09, ESFA have clawed back the on-programme month for April and now I am worried I have used the wrong codes.

The learner has finished learning activities but has yet to sit EPA and therefore the outcome is unknown. We therefore completed with the following codes:

Learning Actual End Date: 17/03/2022

Completion Status: 1 Continuing 

Outcome: 8 Not Yet Known

I thought this was correct as on our Pellcomp system it shows as "EPA" in the status column. 

I have raised this with ESFA support but any help you can offer would be much appreciated. TIA.


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Hi Jessica

What was their Planned End? I'm guessing it was in April (or later)? When learners go to Gateway "early", the On Progs stop and then you get a balancing payment with the completion payment.

Martin West

This is correct as the end date is march and until the EPA outcome is unknown any outstanding monthly payments are withheld until the EPA is completed.


Jessica De Melo

Steveh Martin West

Thank you both and Steve correct - it was an April PED. I knew I had followed the PSM correctly so the clawback really threw me - what a relief!

Just out of interest... how do providers fair then if the learner doesn't sit EPA? I know we lose the completion payment but would we also lose any oustanding on-programme payments too?

Martin West

If they do not complete the EPA they will be a withdrawal and you would lose any outstanding monthly payments.

Ruth Canham-James

Whilst Martin is absolutely right, you would lose your remaining on programme payments if they complete early but then don't sit the EPA, I did raise this with the Apprenticeship Service as being really unfair. They gave me specific permission for the apprentice in question, to record the Actual End Date as the Planned End Date (instead of the true Actual End Date), enabling us to claim all our on programme payments. I was instructed to keep the email as evidence if audited.

If this happens, it's worth a try asking them for the same. Their specific statement to me was "As you have confirmed that the apprentice has completed all their learning, the Specialist team have agreed in this instance that you can record the withdrawn date as the planned end to allow the balancing payments to be released", but it was just for this one ULN.


(worth pointing out that the initial policy document said it *wasn't* meant to work like this, it was *meant* to give you all the balancing payments at Gateway, but that's just not how they built it, and it was only when we pointed it out that anyone realised and then they changed the policy rather than fixing the system...)

Jessica De Melo

Thanks Ruth Canham-James that's good to know.