To clarify, I don’t think that’s reasonable, but I think it’s what the rules say. Your comment Steve about sticking to a value derived from an inaccurate plan, is absolutely the point. We shouldn’t have to deliver the original hours if it has become clear that the apprentice has raced through everything. It wouldn’t be the first time we’ve been forced to behave in an unreasonable way to meet the rules though.January 15, 2020 at 11:24 am #420615
I am always surprised at the different interpretations that others make.
My interpretation is that the ‘full content of the commitment statement has been delivered’ is not related to the OTJ hours but the learning.
A fast learner would complete before the planned end date and may have completed only the OTJ hours up to that point which will be less than was planned on the commitment statement but this is acceptable to the ESFA.January 15, 2020 at 11:35 am #420619
This is the problem – The ESFA need to consider realistic scenarios when they write these rules to provide clearer guidance as to the approach in different situations, particularly if they are going to be rigid in their response / guidance to auditors (during audit)! And not just respond to queries we raise by restating the funding rules.
I can see both interpretations & my concern is that this was raised & discussed during our audit, yet they still haven’t identified that there are clearly many different providers who are interpreting & implementing the rules differently and provided any sort of clarification.January 15, 2020 at 11:57 am #420629
Just to add another dimension to this debate, a learner does not have to record all his study hours, just enough to meet / exceed the 20%. So they could actually be putting in 40% and finishing early but only recording enough to meet the 20%January 15, 2020 at 1:52 pm #420661
Where does it state that?January 15, 2020 at 1:58 pm #420665
I’d contacted the Service Desk about clarification for this situation recently and they forwarded the query to the Apprenticeship Service Support. The full question I asked and their answer is below, hopefully this is useful for everybody on here:
“Within the Apprenticeship off-the-job training guide (v3), question 79 asks “If an individual completes their modules earlier than the planned duration i.e. a level 4 24 month planned duration but the apprentice completes all modules in 18 months, is this acceptable to the ESFA?” and the answer is “Yes, if the apprentice has, for whatever reason, been able to complete in a quicker timescale, then so long as: a) the full content of the commitment statement has been delivered and b) the minimum training duration threshold of 12 months has passed then this is acceptable. The implication is that either the apprentice is a ‘fast learner’ or more than 20% has been delivered to the individual over a shorter timeframe.”
When it says ‘full content of the commitment statement’, does that include the full planned OTJ? For example, if we have a learner who had an 18 month Target Date and perhaps needed to do 450 OTJ hours by that point, but actually the learner managed to complete the necessary elements in 15 months, it’s probable that the learner hadn’t completed 450 hours by that point. Would we recalculate the OTJ required based on 15 months and ensure that the learner had achieved at least 20% of their working hours for the actual duration they were on programme, or do they need to have achieved the full amount that was calculated assuming they had stayed on programme for the full duration?”
The answer here is that the if the learner completes early, they do not need to have completed the full off the job training hours planned out originally. You would do the following –
“recalculate the OTJ required based on 15 months and ensure that the learner had achieved at least 20% of their working hours for the actual duration they were on programme”
SteveJanuary 17, 2020 at 10:49 am #421291
Can I ask how recently this was confirmed? We had a full assurance audit in September 2019 & the ESFA clarified to our auditors that they must meet the original planned hours. The following was the statement we received:
“The ESFA expectation is that early completion should only take place if the learner has completed the off the job hours calculated over the planned duration rather than the actual duration e.g. a planned duration of 18 months completed in 15 months should see the learner complete the planned number of hours for the original 18 month period”
Incredibly frustrating that advice continues to be contradictory & not clarified!
KateJanuary 17, 2020 at 11:36 am #421320
I received that response from the Apprenticeship Service earlier this week…
SteveJanuary 17, 2020 at 11:54 am #421331
You’re not going to believe this everyone, but I finally got a response from my initial 5 December query TODAY!!! Amazing scenes…July 20, 2020 at 4:06 pm #453774
I think they’ve now resolved this in the funding rules for 20/21 & the flow chart for OTJ (P63-65) where we need to obtain an employer statement if they haven’t met their original planned OTJ for planned duration but have met at least 20% of the actual duration if this is a shorter time period.
Assume your response received supports this?July 20, 2020 at 4:31 pm #453777
Yup, that’s exactly what it says.
(I’m a big flowchart fan!)July 20, 2020 at 4:56 pm #453781
It’s good to see we have some clarification on this & it’s great that a sensible approach seems to have been adopted!July 20, 2020 at 5:20 pm #453788
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