Ruth Canham-James
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Ruth Canham-James commented,
Ah, I misunderstood as you were talking about full level 3.
Ah, I misunderstood as you were talking about full level 3.

Ruth Canham-James commented,
I think the 1st April 2021 refers just to the non-full quals in the offer, it specifically says "that qualification must have been achieved before 1at April 2021". Anyone who has achieved a full level 3 at any time wouldn't be eligible by that route. Not 100% the same question, but when ESFA first split the prior attainment Level 3 options into 5 (non-full level 3) and 6 (full level 3), I pointed out that there were quals that could fall into both. A "QCF Diploma at level 3" sits in 6, but if that specific qual doesn't have legal entitlements, it falls into 5; "Vocational and technical qualifications at level 3 (not on the level 2 and level 3 legal entitlement list)". The answer I got back from the ESFA service desk was; On checking the qualification out on Ofqual, it is clearly displayed as a Vocationally-Related Qualification, and is not in the legal offer where it would be classed as a full level. This means you will use code 5 as its available within 16-19 and loans offers only on LARs and FaLA. It is confusing because it mentions Full level 3 (code 6) when fullness is only attached to qualification that go into the legal offer. "Fullness is only attached to qualification that go into the legal offer". That's a huge change to what constitutes Full Level 3, that went rather under the radar, and it means that if a student has a whole Level 3 Diploma, but it's never had legal entitlements, you code that as prior attainment 5, and they're eligible for funding for a first full level 3.
I think the 1st April 2021 refers just to the non-full quals in the offer, it specifically says "that qualification must have been achieved before 1at April 2021". Anyone who has achieved a full le...

Ruth Canham-James commented,
I'm really curious to know why they added this rule. Surely they can just ignore it if they don't want to consider any amount above band maximum? Also, we're going to have to misrepresent one price. I've assumed keep the assessment price what it would have been, and reduce the training price to your whole price minus the assessment price? If you later get an unexpected discount on the assessment, do you adjust the assessment price, then also have to adjust training price to still make your total be band maximum? And then as you've both pointed out, what about PMR? That won't match the finance records. It's already bad enough trying to record PMR when an employer pays in instalments. We record all the PMR records as training until that covers 5% of the TNP1, then start on assessment after that. There's often one PMR payment we have to split. It seems pretty odd that PMR records even need recording as training or assessment. But I agree with Steve that you will only need to record PMR to cover the required employer contributions up to band maximum. I don't even want to think about how we would manage this is we charged a levy payer above band maximum, and they fell into insufficient funds!
I'm really curious to know why they added this rule. Surely they can just ignore it if they don't want to consider any amount above band maximum? Also, we're going to have to misrepresent one price...

Ruth Canham-James commented,
This is a really common misconception, driven I think by the fact that many EPAOs choose to charge exactly 20% of the band maximum for the EPA, because the guidance says "It is expected that the cost of the assessment will not usually exceed 20% of the funding band maximum". We do have many that charge less than that. TNP 2 is the Assessment price, it's what you'll be paying the EPAO. So, as Martin says, if you're agreeing a reduction to your Training price, that's just on TNP 1.
This is a really common misconception, driven I think by the fact that many EPAOs choose to charge exactly 20% of the band maximum for the EPA, because the guidance says "It is expected that the co...

Ruth Canham-James commented,
If you don't fix them, or they're not fixable, they will show up the following month, it's cumulative. We have loads of things on those reports that aren't errors. If you get anything in FRM27, that's definitely not fixable unless you genuinely made a mistake with your end date, and it was actually in the current year rather than a previous one. We just export to excel, make notes against each row that didn't require a correction, and then compare with next month. We transfer notes onto the next month list where the row is still there, then work on new things.
If you don't fix them, or they're not fixable, they will show up the following month, it's cumulative. We have loads of things on those reports that aren't errors. If you get anything in FRM27, tha...

Ruth Canham-James commented,
Any data in the PLR that came from ILR data (or NPD I guess) rather than the awarding body, won't have an award date. As long as the grade is a pass, and/or the Outcome is Achieved, you can accept it. The complication comes when the ILR data was entered by a provider who chooses not to enter a grade for qualifications that are a straight pass/fail, as the grade is not technically required as you indicate the pass/fail using the Outcome field. So you do need to also check Outcome, as a blank grade could also be a pass.
Any data in the PLR that came from ILR data (or NPD I guess) rather than the awarding body, won't have an award date. As long as the grade is a pass, and/or the Outcome is Achieved, you can accept ...

Ruth Canham-James commented,
Were they entered as a pass? If so, what achievement date was used? When in 2021? If on or after 1st August, then yes switch to 1/8. If it was before 1st August, I'd say contact ESFA. If you reported a pass, that'll be in the PLR which will need resolving, and you can't do that by changing the ILR if it was in a closed year, so you'd have to contact the LRS too. If you coded it as a fail, and will now report a pass, less of a PLR issue. The employer change may or may not be an issue. If you already mistakenly claimed the completion element, that's something ESFA will have to advise on as they may want to claw it back, but if it was in last year, they'd do that manually, so there would be nothing left in the band maximum to charge a new employer.
Were they entered as a pass? If so, what achievement date was used? When in 2021? If on or after 1st August, then yes switch to 1/8. If it was before 1st August, I'd say contact ESFA. If you report...

Ruth Canham-James commented,
We certainly try and get the employer to pick the EPAO and agree a price before the apprentice starts. I don't actually deal with the EPAO registrations, but I think it varies wildly from EPAO to EPAO. I know some insist we register within 6 months of the start date (even on a two year apprenticeship), and we pay some up front, some later on. Sometimes there may have been a loose agreement, which I suppose could then change, but I'd still enter that value from the start. It would be more than an estimation, it would be "the correct information to the best of my knowledge". We do have a scenario where one EPAO offers a discount if you put two apprentices through at once. We won't know for sure until very close to the gateway whether we'll have two ready to complete at the same time. So, I've just put the higher price down as the Assessment price, as that is what has been agreed, but there's a chance we'll need to reduce it later on if we get a late discount.
We certainly try and get the employer to pick the EPAO and agree a price before the apprentice starts. I don't actually deal with the EPAO registrations, but I think it varies wildly from EPAO to E...

Ruth Canham-James commented,
You've never been allowed to estimate the Assessment price, but the 22/23 rules have clarified; P96.1 The employer and the end-point assessment organisation agree the price of the end-point assessment (which is entered by the provider in field TNP2 on the ILR only when the actual cost is known; estimate costs must not be entered). Yes, you have to get the employer to agree the price twice in the DAS if you don't know the assessment price up front. You just enter your Training price to start, then when you add the Assessment price, it will lock and they have to approve again. If the Assessment price ends up being less than expected, you shouldn't increase the Training price to meet band maximum (it would be hard to explain to the employer, why you'd just hiked the price). If the Assessment price ends up being so high it takes your total price over the band maximum, based on the new rules for next year, you'd only be able to report a price up to the band maximum, so I guess you'd just report an Assessment price lower than reality? Alternatively, you'd have to add TNP2 and add a new, lower, TNP1. That's something we should probably get clarified.
You've never been allowed to estimate the Assessment price, but the 22/23 rules have clarified; P96.1 The employer and the end-point assessment organisation agree theprice of the end-point assessm...