[Cris HaleSpectator]

Better still to know what you need and what you don’t, I say! My boss is in agreement with you though, which is why I’m only really interested in finding out how much pointless work we’ve done, rather than bothering to avoid doing it.

[Cris HaleSpectator]

That’s always the way, isn’t it? They presumably confuse matters in an attempt to push you into going overboard – it’s certainly rare enough that they make things simple!

Looking at the funding rules for 2017-18 I’m getting a strong feeling that the written agreement was only to specify who does what where subcontracting is involved. But then the glossary has a description of a contract with the EPA Org under ‘Written Agreement’, so that’s unhelpful.

It’s a similar story in the 2018-19 rules, and again the written agreement is identified as being specifically about subcontracting yet is the first thing mentioned in the evidence pack requirements.

As for the 2019-20 rules, they are equally unclear. The written agreement is only really detailed under the subcontracting section, but then it is listed under the main evidence pack list and the subcontracting section of that (312). 307 simply makes a point of what should be in the agreement, 311.1, as you say, is typically poorly worded so as to be unclear.

I guess if we weren’t all stumbling around in the dark, they wouldn’t be able to hit us with sticks without fear of retaliation. Oh wait, that was just a dream.

Cris

[Cris HaleSpectator]

Hi Gaynor,

But that page does specify that the agreement is for employers wishing to use the apprenticeship service, which again seems to suggest that funding under a normal ESFA contract may not require one.

That agreement is also between the ESFA and the provider, having nothing to do with employers themselves…

Cris

• This reply was modified 12 months ago by  Cris Hale.

[Cris HaleSpectator]

We received one, but the dates had been changed by mistake so it was pretty timely for us, being just before the submission deadline.

[Cris HaleSpectator]

Hi Laura,

Many thanks – I’ve bookmarked it for good measure.

Cris

[Cris HaleSpectator]

It’ll be interesting to see what sort of fines are levied, given the general panic over GDPR since it came into effect. I have to assume there’ll be some, even if they’re partly to make a statement owing to the high profile of the incident.

[Cris HaleSpectator]

Hi Sue,

You can use a ULN of 9999999999 for non-Levy-funded learners for the first 60 days, I think it is. I imagine it will be restored by then. Alternatively, just leave them all blank until it comes to the final upload and hope it’ll be restored by that time!

Even if it’s not restored, they’ll surely have to temporarily allow the absence of a ULN because I can’t see them bringing the whole industry to a halt!

Hope that helps,

Cris

[Cris HaleSpectator]

Hi Martin,

If I can revive this thread, where does this information come from? Is it all from this link, which doesn’t appear to specify what it apples to?

And you said that apprenticeships from May 2017 are not used for match funding – I assume that means the ones before then are?

Any idea how I would find out about the retention period for apprenticeships before 2014?

Thanks in advance,

Cris

[Cris HaleSpectator]

Hi Ruth,

I feel like there was a crossover period where they’d give both types of grading and I had thought it was one of those, but they may well be S&L grades. Come to think of it, I have seen certificates where they provide one separately (the example above is from the Learning Records Service).

I think I will take it as a C unless I hear otherwise…but perhaps I should send it to the EPA organisation and ask their opinion, as well. They’re the ones who’ll decide on it ultimately.

Thanks,

Cris

Edit: Just looked up the qual code and it appears it is given with a S&L grade – should have thought to try that before… Thanks, Ruth!

• This reply was modified 1 year, 5 months ago by  Cris Hale.

[Cris HaleSpectator]

Hah! I saw that. I wonder how often it comes up.

[Cris HaleSpectator]

Hi Martin,

Thanks for that. So that seems to be available under the list of qualifications approved for funding (which is a slightly odd place to put something that includes saome overseas qualifications, but we’ll look past that). I actually have the page bookmarked, but I didn’t know it was there… Don’t know why there’s no link from the funding rules pages – or none that I could find.

Cris

[Cris HaleSpectator]

Thanks, Caspar.

They may have put in in an update, but they really need to declutter/personalise those – why does it matter to me which providers are in special measures? I have no idea why they’re giving us all updates on that. It would be nice to get information relevant to me, rather than everything they do. Ah, well.

Cris

[Cris HaleSpectator]

Hi Erica,

It is only a warning for not having an EPA recorded at all – I think that changes to an error when you’re two months away from the predicted end.

I would suggest adding one or two EPA Orgs and submitting an ILR return to see if you get an error – if you do, you can just undo that and hold off on entering them until this is all sorted out.

Cris

• This reply was modified 1 year, 6 months ago by  Cris Hale. Reason: Question of time

[Cris HaleSpectator]

Absolutely – otherwise, as you said, we’d risk claiming funding for training we weren’t delivering and that’s one of the few things the ESFA’s guidance is crystal clear on!

[Cris HaleSpectator]

Hi both,

Martin, somehow I’d missed the bit you highlighted from Note 4 on the Apprenticeship Agreement template. That does seem to answer everything. And I did notice that rule, P25, earlier today. I think the new start date does make sense in that respect.
Also, with regards to your last point, we used to set both dates the same for a time after they amended the template to have both, but have started making the non-practical start date the start of employment for exactly the reasons you’ve mentioned here.

Ruth, I wouldn’t say it was fraud – our candidates recruited as apprentices have always been counted as apprentices prior to their enrolment, and they’re aware of it. In situations where the employer has started to take liberties with their ‘trial periods’ we’ve cut ties in order to protect candidates from exploitation. We also make it completely clear that if the candidate doesn’t start their apprenticeship they must be paid the normal minimum wage. I’d say it was just an administrative convenience – albeit one that requires keeping an eye on. I might add that I had eleven days of this before my own enrolment when I started here, and I don’t feel wronged in that sense.
It’s different with pre-existing employees, of course – I think in that case there’d be no excuse for setting the start date earlier, but then I’d be a pretty miffed employee if my pay got downgraded, as well!

Cris

• This reply was modified 1 year, 7 months ago by  Cris Hale.

[Cris HaleSpectator]

Hi both,

I’ve just been looking at the 2019-20 documents and come to this issue. So I’m taking it from your conversation that it’s unresolved…

I thought the introduction of the term ‘practical period’ would aid clarity, but I suppose that’s only the case if they bother to use it. So the question is: is ‘start date’ referring to the apprenticeship or the practical period? And if they want us to record that of the apprenticeship overall, why on Earth aren’t they putting both dates in the ILR?

I think we’ll bank on continuing to use the start of learning (as delivered by us) as the start date. Why change until they’re clear about what we should be changing to? They’re clearly flailing about over it anyway – in paragraph 65 (c) of the 2019-20 V1 rules they’ve missed out a full stop where they added the bit about the dates matching. If they didn’t even re-read what they’d written, how seriously should it be taken?

Also, I find it interesting that the ILR spec says of the start date that it “could be at any time during a programme”. That suggests that it’s not necessarily at the start of the programme, doesn’t it?

Cris

[Cris HaleSpectator]

Hi Martin,

I had a suspicion, but I wasn’t sure, and – as you’ll have noticed – the guidance doesn’t say what the non-specific start date is, only the one we could have figured out ourselves. I guess it’s intended for employers, but why bother not explaining it…?

Thanks,

Cris

[Cris HaleSpectator]

Hi Natalie,

I am getting this rule, but I think it must be in error. I have no way of knowing though, as the register of EPA Orgs doesn’t say anything about what dates they apply to, as the validation rule does.

Where can I get this information? I’m fairly sure it must be wrong.

For example, I have a completed learner who did the EPA for his Business Administrator standard this January who is triggering the warning. City and Guilds (EPA0008) are entered as the EPA Org, and are the ones who conducted it. I can’t really change it now – it has already happened.

Thanks,

Cris

[Cris HaleSpectator]

Actually, another query for you – should I count the assessment costs before moving onto the training costs. As an example:

Original training cost is £900, original assessment cost is £90. 20% of the total, £990, would be £198. Would I go with TNP4, residual assessment cost, of £90 and TNP3, residual training cost, of £108?

That would seem the logical route, but that assumes we’re supposed to act logically, which I have no evidence for.

Cris

[Cris HaleSpectator]

Hi both,

Thanks for your advice. I think I will go with that and see what happens.

Cris

[Cris HaleSpectator]

Thanks, Martin – Apps Indicative will do nicely.

Cris

[Cris HaleSpectator]

Thanks, Ruth.

[Cris HaleSpectator]

Hi Rob,

It’s perfectly common for any employer to not have ERNs for any sites. It is less likely than with non-levy companies, as they have frequently had training before, but I wouldn’t say it was cause for concern. I am slightly confused by your use of the term ‘levy ERNs’ – there’s no distinction between ERNs for Levy and non-Levy companies. I would suggest that you just add new records – they will need verifying anyway, so any concerns you have could be listed in the notes for the EDRS guys to check out.

If that answers your question then this bit isn’t important, but what do you mean by ‘Levy transferee’? It sounds like you mean the new employer, but you’ve said the learner doesn’t work for them? Do you mean to say that one of your levy clients is tranferring some of their pot to another employer? In that case, I don’t believe anything would need to be recorded on the ILR as that is between the levy-paying companies and theoretically nothing to do with you, but I would appreciate confirmation from a third party.

Hope that helps,
Cris

• This reply was modified 1 year, 11 months ago by  Cris Hale. Reason: sign-off

[Cris HaleSpectator]

Martin – That rule also looks quite a lot like it refers specifically to component aims, so I wonder.

Ruth – That’s an interesting point. So would you suggest the visit where learning of the new aim was begun as the ‘changeover date’, then?

[Cris HaleSpectator]

Hi Martin,

Thanks – I’ve taken a look at that section. It would be helpful if it said whether more specific paragraphs (for example, for apprenticeships over learning in general) superceded less specific rules. As it is, they may contradict or they may not.

I found the following rule which applies generally, and includes a reference to the programme, but it’s not clear whether it still applies to apprenticeships:

417. If a learner transfers to another programme or learning aim after the funding qualifying period, then the original learning aim record(s) will need to be closed and new learning aim(s) added: see Table 4. You should not just amend the details on the original learning aim(s).

I think in the absence of any specific information about how the funding qualifying date is applied I might opt to play it safe, but I’m not happy with the extra complication if it isn’t necessary!

Cris