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Created 18 May 2022 14:07
We've just had a scenario where we've been quoted prices for an EPA, that varies depending on whether it's one student, or a pair on the same day. We probably won't know until close to the end which price we'll be paying, because we won't know if the students are ready to sit their EPA at the same time. I'm thinking record the higher single student rate for now, and then update later if we get a discount. Will I be able to create a new Assessment TNP with a data after the Actual End Date of the apprenticeship?
I then started thinking whether we would even need to bother, because it's called Assessment Price, not cost. I do think we have to change it, because if we don't, we essentially get to keep more than the agreed training price for ourselves, when we should actually be passing that discount on to the employer. Surely that's not allowable? If audited, do they check that our payment to the EPAO matches the Assessment Price exactly? I know they are supposed to check we made the payment. Some staff try and suggest we increase the training price to match the original price when we reduce the assessment price, but that's not happening. How would we justify increasing our training price at the same time that we "coincidentally" got an EPA discount?
I know in theory the employer is supposed to choose the EPAO and negotiate the price, but in reality, almost every single employer we've ever had just wants us to arrange it for them.
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If because of provider discounts the EPA price is reduced the following from the ILR specification notes would apply.
If a new price for training, assessment or both is negotiated then you must add new TNP records. The financial record date must be set to the date the new price is effective from.
As this date would be prior to completion it should not be an issue.
18 May 2022 14:46
But the change could feasibly be after completion. Student gets to gateway, we've assumed the price is the price for one student at a time. There's a delay in the EPA starting. Two days later, another apprentice finished early, meaning we can book them in at the same time as the other apprentice, and we suddenly get a discount.
Would you agree that, fundamentally, the assessment price should always reflect exactly what we really are going to pay the EPAO (to the best of our knowledge)? I get the feeling that there's a habit amongst providers of just recording an assumed price, often 20% of the band maximum, and it not being adjusted later when it turns out to be lower. That essentially gives providers a secret bonus payment, which doesn't seem right, we were only ever supposed to get the Training Price to keep. However, nowhere in the guidance does it explicitly state that the Assessment Price should match what we pay the EPAO exactly, which makes me question whether ESFA would even check this.
18 May 2022 15:03
It is normal practice for EPAO that the registration price will be invoiced to the Lead Provider on selection of the EPAO by the employer. The remaining EPA price is normally invoiced to the Lead Provider ahead of the gateway review to commence end-point assessment per batch cohort this should enable any price change to be reflected in the ILR prior to actual completion but this will require processes to be in place to capture any change in the original price agreed.
That’s the theory but in practice I have seen little evidence of actual EPA price changes in ILRs due to batch cohorts discounts.
19 May 2022 08:18