Learning actual end date for withdrawal during EPA

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Home Forums Data issues Learning actual end date for withdrawal during EPA

This topic contains 21 replies, has 5 voices, and was last updated by  Cris Hale 2 years, 1 month ago.

Viewing 22 posts - 1 through 22 (of 22 total)
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  • Cris Hale
    Spectator

    Hi all,

    Just wondering what people’s thoughts are on withdrawing a learner who has attempted and failed the EPA. The ILR spec says of the ‘Learning actual end date’:

    For programme aims, the Learning actual end date of the whole programme must be recorded in this field. For apprenticeship standards with a Completion status of ‘complete’ (code 2), the Learning actual end date for the programme aim is the date that the learner completed all the learning activities for the apprenticeship. This includes both the training and end point assessment activities.

    Obviously “For apprenticeship standards with a Completion status of ‘complete'” doesn’t apply if they don’t have a status of ‘complete’, so are we thinking this was just poor wording, and that a learner withdrawing after attempting EPA would have the EPA date as their actual end?

    The Provider Support Manual is also of little help, the generic section says “aims should be closed”, as does the section specifically about funding model 36 – nice redundant repetition, there – but neither has anything about the end date, and the section about apprenticeships regadless of funding model has nothing.

    If you listen very quietly you can almost hear the auditors telling people off for not following the rules that haven’t actually been written down anywhere.

    Think I’d just have to withdraw them to the EPA date – anyone have any other ideas?

    Cris

     
    #352457

    Martin West
    Spectator

    Hi Cris,
    Complete includes those who pass, fail and are awaiting results, they do not have to Pass to be a completion, but they must be recorded as a completion to attract the completion payment, if you record them as withdrawn you will not get the 20% completion payment so that you can pay the EPAO.
    HTH

     
    #352468

    jessc21
    Spectator

    Hi Martin,

    Where is that stated?

    Thanks,

    Jess

     
    #352474

    Martin West
    Spectator

    Hi Jess,
    In the PSM:
    Recording apprenticeship standard completions
    621. For apprenticeship standards, when all of the training and end point assessment elements have been completed, the following should be recorded:
     All the component learning aims within the programme must be closed with the Learning actual end date set to the date of the last learning activity for the aim(s).
     The programme aim must be closed with the Learning actual end date recorded as the date the end point assessment for the programme was finished.
     The Date applies to must be recorded on the latest Apprenticeship contract type FAM record as the same date as the Learning actual end date for the programme aim.

    622. When the apprenticeship standard is achieved, the aims must be updated as above and the Outcome on the programme aim recorded as code 1 ‘Achieved’.

    623. All open and closed learning aims that are part of the apprenticeship standard programme must be returned on the ILR until the standard is completed.

    624. In order to be recorded as ‘Completed’ (Completion status code 2), both the training and end point assessment activities for the programme must be completed. If either of these have not been completed, then the programme aim cannot be recorded with Completion status code 2.

     
    #352501

    Cris Hale
    Spectator

    Hi Martin,

    I see the distinction – I was thinking code 2 was for a pass outcome, but of course it separates completion status and outcome. So do you suggest the following?

    Learning actual end date: the date of EPA
    Completion status: 2 (the learner has completed the learning activities)
    Outcome: 3 (No achievement)

    We have done that with the level 2 functional skills where a learner was unable to achieve them, but didn’t require them to achieve the programme. I suppose it would be accurate in this case, too.

    Thanks,

    Cris

     
    • This reply was modified 2 years, 1 month ago by  Cris Hale.
    #352592

    GeorgeC
    Spectator

    Hi Chris,

    as an auditor with experience of ESFA audits if I saw evidence to demonstrate that a learner had not passed the EPA and completion status 3 (withdrawn) recorded in the ILR I’d query with the provider why they had potentially understated their funding and not used completion status 2, outcome 3 (completed, no achievement).

    My personal approach to ESFA funding audits is to understand the observations that are being raised and why they are being raised (what controls are in place / failed, is this a systematic misunderstanding etc). I prefer to have a dialogue with, rather than “tell off” (that’s just me though).

    The latest audit working papers are aligned to the ESFA’s documentation, so in theory you should never be in a position where you don’t understand an observation that has been raised, or at least be able to have a conversation with the auditor to understand their position. There’s also an escalation route to the ESFA if you fundamentally disagree with an auditor interpretation of the funding rules so the ESFA ultimately make the final decision on the evidence observed versus the funding rule in question.

    If I saw an ILR status of Completed no achievement (2, 3) on a learner who had evidence that they had failed the EPA (without direct guidance/ clarification stating otherwise) I would accept that the data was accurate from an audit test perspective.

    Hope that is useful.

     
    #352619

    Cris Hale
    Spectator

    Hi George,

    So are you saying that recording as completed, withdrawn gives you the completion payment? I had assumed that it was based on successful completion; but that’s not the case?

    As an auditor, these unwritten rules must make it more complicated for you, too. I didn’t even realise you could put a completion status of ‘complete’ for learners who haven’t achieved until I asked the ESFA how to record a special case. I’m still not aware that there’s anywhere in the documentation that says when it would be appropriate to do that, or indeed that it’s acceptable to do so.

    I probably wouldn’t be involved in an audit – I wasn’t with the last – so it would be best if everything was clearly by the rules, but I suppose if there were an issue I might be asked about it.

    Thanks for your advice – I don’t usually get an idea of what an auditor would say about things.

    Cris

     
    #352628

    GeorgeC
    Spectator

    Hi Cris,

    not necessarily, as minimum and actual duration are also factors and it would depend on whether the learner was actually completed and finished (per your example) or went on to achieve at a later date, although I understand there is a timeliness issue in generating the achievement element in this scenario.

    As auditors we’re not a the sharp end so to speak as we are generally looking backwards at the data and reconciling it to the underlying evidence provided. As a result we often talk about potential funding errors / impacts, which are essentially data errors which could have an impact on funding.

    In the instance above if you withdrew the learner instead of recording them as completing with no achievement there is no possibility of attracting any “achievement” funding.

    From memory I think that achievement payments are only made when the ILR record is completion status 2, achievement status 1 (however would be happy to be corrected) and on FM36 we haven’t audited any achievements as of yet.

    Sorry if I’ve confused things! But would be happy to have a chat offline if that would be of assistance.

     
    #352639

    Ruth CJ
    Spectator

    There’s no such thing as completed, withdrawn. Those are two mutually exclusive Completion Statuses.

    The Completion payment is for when Completion Status is 2-Completed. For Standards, you can only record that once they’ve done the EPA. If they don’t do the EPA, they’re Completion Status 3-Withdrawn, which doesn’t release the completion payment. You do get completion payments for Completion Status 2, and Outcome 3-No achievement.

    Completion Status has always been an indicator of whether the student finished, regardless of outcome. The definition is “The learner has completed the learning activities leading to the learning aim”. The ILR Spec also specifies that this means having completed the EPA for Standards. I think that’s really clear.

     
    • This reply was modified 2 years, 1 month ago by  Ruth CJ.
    #352641

    Cris Hale
    Spectator

    Hi both,

    George – The technical funding guide refers you to the funding rules for a definition of completion, but the best I can find on the topic is:

    We will pay the remaining balance of the total negotiated price, up to the maximum value of the funding band, when the apprentice has undertaken all the activity relevant to the apprenticeship, including:
    all mandatory elements of the framework; or
    all elements of the end-point assessment for standards.

    Which could suggest that ‘completed, withdrawn’ isn’t a thing – although again, it says ‘undertaken’, not passed.
    The technical funding guide’s own wording is

    We hold back 20% of the total price, capped at the maximum of the funding band, for completion.

    which is about as technical as a rock.

    Ruth – There are contradictions there, though. For example,

    The Completion payment is for when Completion Status is 2-Completed. For Standards, you can only record that once they’ve done the EPA.

    In our case she has done the EPA, hence the question over what to put in the rhetorical case of her withdrawal. The problem is completion status 2 is not simply completed, but ‘the learner has completed the learning activities’, which she has. The confusion may simply arise from the ESFA’s reluctance to specify whether they mean ‘learning, not including assessment’ or ‘learning and assessment’.

    Cris

     
    • This reply was modified 2 years, 1 month ago by  Cris Hale. Reason: Amended
    #352921

    Martin West
    Spectator

    Hi Cris,
    I do have to agree with Ruth over this but it’s all change for next year
    Learning actual end date:
    For apprenticeship standards, for continuing learners with a Learning Actual End date on or before 31 July 2019 this date must continue to include the training and end point assessment period. For continuing learners where all learning activity has ended on or after 1 August 2019, the learning actual end date must be the end of learning only and must not include the end point assessment period.
    Outcome:
    For apprenticeship standards, learners that start on or after 1 August 2019, Code 8 ‘Learning activities are complete but the outcome is not yet known’ must be used at the end of learning and prior to the end point assessment period. Once the End point assessment has taken place this is then updated accordingly.
    Achievement date:
    This field is now going to be collected for Apprenticeship standards (FundModel 36, ProgType 25)
    This field will be used to record the end of the apprenticeship standard. This date concludes the End point assessment period. Once this date is returned the Completion status and associated Outcome must be updated accordingly.

    Not sure on the last one if we record the Achievement date or just the end date of the EPA as it says the outcome must be updated accordingly, hopefully this will be confirmed in the PSM once published.

    I think the changes are to enable the inclusion of timely achievement in the QAR for 2019-20

     
    #352999

    Ruth CJ
    Spectator

    Hi Cris,

    How is that a contradiction? Those things you quoted are all saying the same thing. The only contradiction is if you think that the EPA is not “learning activities leading to the learning aim”. But Exams also count towards that; you can’t be a completion and fail if you weren’t given the opportunity to sit the exam (that’s been confirmed by an auditor). It’s no different. It sounds like you never record anyone as completed and failed. What does that do to your retention and success?

    In your specific case of an apprentice that sat the EPA and didn’t pass, there’s no doubt in my mind that she’s a completion and a fail (Outcome 3). You should absolutely get the completion payment. What part of the guidance makes you think otherwise?

    However, Martin’s right about that change for Standards next year though. If the actual end date will no longer incorporate the EPA, then ESFA have obviously decided that the EPA will in future not be counted as learning (where it always has been before). The definition of Actual End Date is “The date that the learner completed the learning activities necessary to achieve the learning aim”. If EPA is after the Actual End Date, then by definition, the EPA is not a learning activity. That means that the definition of Completion Status does not include the EPA. Therefore, it’s even easier to complete a Standard. As long as they get to the Gateway, they are Completed, even if they then don’t actually do the EPA! If ESFA want to argue that, they need to change the definitions in the 19/20 ILR Specification.

     
    #353026

    Ruth CJ
    Spectator

    Martin,

    This bit;

    Achievement date:
    This field is now going to be collected for Apprenticeship standards (FundModel 36, ProgType 25)
    This field will be used to record the end of the apprenticeship standard. This date concludes the End point assessment period. Once this date is returned the Completion status and associated Outcome must be updated accordingly.

    What update would we ever need on the Completion Status? Once they’ve actually finished (gateway), we’d record their Actual End Date and a Completion Status of 2. There’s no other status to use. You can’t record an Actual End Date with a Completion Status of 1 (validation Rule CompStatus_02). Why would we ever update that upon Achievement? We won’t suddenly decide they didn’t finish the learning activities after all.

     
    #353030

    Cris Hale
    Spectator

    Hi Ruth,

    [In the square brackets is stuff I’ve added after I understood what you were saying. Now this I would call a learning experience!]

    I should have taken that out – I was going to quote your first sentence about there being no ‘completed, withdrawn’ status, which seemed [before I wrote this post] to contradict the idea that ‘complete’ should be used after EPA (in this case of a hypothetical [what I thought was a] withdrawal).
    But without more specific wording I wouldn’t consider the EPA to be ‘learning’ any more than using a kettle you’ve never used before. It’s an experience, sure, but not course-related and not with the aim of teaching the apprentice. The documentation should be more specific, I’d have said.

    We used to record anyone who didn’t pass as withdrawn – and, as of today, still do for all main/programme aims. Then I brought a query to the service desk and they told me to record a functional skills aim as learning complete with no achievement and we started using that where it applied. I’ve never come across anything in the guidance that suggested you shouldn’t use the ‘withdrawn’ option for learners who withdraw [which we’ve always equated to no achievement]. It seems counter-intuitive, even if ‘completed the learning activities’ also describes the situation.

    The big no-no is playing the data to get funding that you weren’t entitled to, and without ever having read otherwise in the guidance, that’s what this seem[ed] like. That said, I didn’t think you got the completion payment if they didn’t achieve anyway – not because any part of the guidance makes me think so (it seems like common sense – don’t achieve, don’t get achievement money), but because no part of the guidance I’ve seen made me think otherwise.

    What does that do to your retention and success?

    Are you also telling me that if they complete with no achievement that they’re considered a success?

    I shouldn’t be surprised if it turns out nothing works the way we thought it does – I mean, our finance/operations person has been trying to tie together the Apps Indicative report, the Monthly Payment report, and the funding actually paid to us with its limited breakdown by contract, and we still haven’t got the much of a clue what they’re paying us for (or not) because none of them ever match up – but this all seems like something that should be specified in the documentation.

    So, I guess I should ask one other question – even if it might open another barrel of worms – but does that mean the withdrawal status is not also for learners who attempted to complete but were unable to? I was under the impression that if they couldn’t pass you could theoretically keep trying to get them to pass ad inifinitum, therefore if you closed them down you were withdrawing them from the programme.

    Cris

     
    • This reply was modified 2 years, 1 month ago by  Cris Hale.
    #353140

    Martin West
    Spectator

    Hi Cris,
    I think you still misunderstand so I will put it in the context of delivering a standard qualification aim.
    You plan the delivery of the aim backed up by a curriculum plan and registers which cover the course content and period of training. Where the planned course is completed that is they completed all the learning and this is backed up with registers then they have completed but could have either achieved or not achieved. If they do not complete the course, then they have either withdrawn from it or where they have achieved early have completed and achieved.
    This is the excepted approach used by Providers and funding rules and audit in FE and training over many years and the same applies to Apprenticeships and it is only a completion payment not an achievement payment that applies.

    HTH

     
    #353149

    Cris Hale
    Spectator

    Hi Martin,

    Well that gives me a lot to think about – although with the backlog of EPAs from the switchover, I don’t think we have anybody from this contract year who will need to be revisited. Some of the previous ones probably should have been, had that been possible, but luckily it’s quite rare that we have people complete learning without achieving.

    What I was originally asking for – I may as well explain it after all that – was to find out whether a failed EPA that occurred after 365 days on programme (obviously) would mean that, were they to withdraw, the employer would be able to keep the 365-day incentive payment, since the last other evidence was a short time before the 365-day mark. It seems like the answer to that is ‘yes’.

    Thanks,
    Cris

     
    #353153

    Ruth CJ
    Spectator

    Honestly, this is really interesting. There’s so much I learned from my predecessors that I take for granted. Had I learnt this all myself, who knows if I’d have the same understanding.

    I like Martin’s explanation. We actually revisited this lately. We’d always gone with the assumption that, if you’d hit your planned end date, and didn’t pass, you were a fail. Not necessarily. On a full time classroom based course with registers, almost certainly yes. On some courses, it might be that you’re three months past your planned end date, but still haven’t done all the learning required. If you then quit, that’s a Withdrawal after the planned end date. On the other side, just because you stopped learning before your planned end date, doesn’t mean you’re a withdrawal. We’ve got a group of students who’ve raced through all their content, and are sitting their assessment really early. If they fail, as you say, we may choose to leave them continuing and let them try again, which is fine. If we know they don’t plan to try again, we’d code them as a completion and fail, not a withdrawal. The Planned End Date doesn’t strictly have any bearing on whether something is a completion and fail, or withdrawal.

    Excuse my ignorance on achievement stats (not my area), but don’t withdrawals count as not retained? If you started coding some of your students as completion and fail, wouldn’t your retention rate go up?

    The Completion payments for apprentices since May 2017 is a new concept. I don’t remember having completion payments before, it was always achievement if anything. It was a big thing with the apprenticeship reforms, that achievement no longer mattered for that payment, just Completion. I think the logic was that sitting the EPA incurs a cost whether they pass or not, so we need the money to pay for that. The statement in some of the funding guidance says;

    33. We are extending these arrangements to standards recognising that some of the
    cost of delivering the standard falls towards the end of the apprenticeship in the form of
    the end point assessment. 20% does not represent the anticipated cost of end point
    assessment, which will vary between different standards. For standards the final payment
    will be made once the end-point assessment has been completed.

     
    #353197

    Ruth CJ
    Spectator

    Oh, and in answer to your actual question, as the rules stand this year, yes. The Actual End Date isn’t until after the EPA has happened, so the additional payment will go through whether you think you deserve it or not. From next year, based on the changes Martin has outlined, it would be a no. The Actual End Date will be before the EPA, and will be your last evidence date of learning before that.

     
    #353201

    Martin West
    Spectator

    Hi Cris,
    You asked, ‘What does that do to your retention and success?’

    This is how success rates are calculated from the ILR data, you will note that where you record completions as withdrawals this will have an adverse effect on your retention and pass rates.

    The overall QAR is the number of achieved learning aims as a percentage of the total number of learning aims in the cohort that ended.

    The overall pass rate is the number of achieved learning aims as a percentage of the total number of learning aims that have completed all the planned learning activities.

    The overall retention rate is the number of learning aims that have completed all of the planned learning activities as a percentage of the total number of learning aims that ended.
    HTH

     
    #353217

    Cris Hale
    Spectator

    Hi both,

    Sorry for the late response – busy week last week.

    Martin – just FYI, the PSM rule you quoted above about recording standard completions seems to be from an old version (I had version 1, which had it as 615, while the current version, 3.1, has it as 700).

    That’s interesting, Ruth, because I’ve never really paid any attention to the planned end dates. I fill them in and so obviously need to know what our expected durations are, but having people complete on time is Work Based Learning’s business (I’m Admin), so they’ve never been part of my consideration when closing an ILR. Goes back to what you were saying about received wisdom. This is why I think it’s so important that it’s written down how we should be doing things.

    It certainly sounds like our retention rates could have taken a hit over the last few years – hopefully not too big a hit. I process withdrawals, and I do know that the vast majority don’t finish their learning.

    I agree – a completion payment is much fairer for this system. It’s like GCSEs, I suppose – a school can’t guarantee that a pupil will pass, but they still spent two years teaching them and will need the funding for it.

    So with regards to additional payments, I suppose next year we’ll need to ensure that the learners are still in learning after the 365 days, or not only wwould they not get the payment but they wouldn’t meet the minimum duration.

    Thanks, Martin – I always wondered what the difference there was. The statistics aren’t really my area, though.

    Cris

     
    #355053

    Martin West
    Spectator

    Hi Cris,
    PSM 3.1 was for last year, this years latest version is V2.
    HTH

     
    #355067

    Cris Hale
    Spectator

    So it is – not sure if I missed the title or forgot what year it was. At least this brought it up – I was originally still on V1.

    Thanks,
    Cris

     
    #355164
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