Guidance

Financial assurance: monitoring post-16 funding for 2024 to 2025

Updated 31 July 2024

Applies to England

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Understanding our terminology

  • the term ‘we’ refers to Education and Skills Funding Agency (ESFA) and colleagues in the wider Department for Education (DfE)
  • when we refer to ‘you’ or ‘providers’, this includes colleges, higher education institutions, training organisations, local authorities, schools, academies and employers that receive funding from us to deliver education and training
  • we refer to ‘learners’ and ‘students’
  • the term ‘post-16’ includes 16 to 19 study programmes, T Levels, apprenticeships, adult skills fund, support funding and advanced learner loans

Introduction and purpose of this guidance

We monitor data from the individualised learner record (ILR), and other sources such as the school census, the earnings adjustment statement (EAS), funding claims and data shared by the Student Loans Company (SLC). By analysing this data, we can:

  • assure that the provision we buy meets our published funding rules, and taxpayers’ money is used for its intended purpose
  • support the successful delivery and operation of post-16 funding systems
  • inform our standard business processes for assurance, audit, end-of-year payment and reconciliation

Our work is framed within the ESFA business plan and supports our vision that every pound spent on education and skills has the greatest possible impact on ensuring all learners can realise their potential:

  • we provide certainty, so you know what action you need to take, and have clarity on the financial impact of any recoveries we may need to make after year-end
  • we support providers by simplifying guidance, so it is easier to interpret and take the necessary actions to ensure your funding claim is correct
  • we provide robust assurance that our funding has been used as intended, maintaining an active approach to identifying fraud and error within the education and skills system

This guidance lists the areas that we are monitoring during the 2024 to 2025 funding year (1 August 2024 to 31 July 2025) and provides information on how to correct data quality or funding errors. It is for providers that have a funding agreement with us and is aimed at staff who submit data to us and/or review data quality.

You must read this guidance along with any other guidance referred to and take the necessary action to ensure data returns and funding claims are correct. Failure to take the necessary action may impact your funding at year-end. These documents include:

For learners who started before 1 August 2024, please refer to the guidance that applied on the learner’s first day in learning.

There is no set review date for this guidance, however, we will act on feedback, or in-year rules changes to ensure reports are fit for purpose.

How we will use data

We will use the data and any funding claims you submit to assure ourselves that the education and training we buy meets our funding rules and key policy objectives. Monitoring your data in-year helps us to identify emerging issues and resolve them in a timely manner, increasing the quality of data that informs other in-year processes.

If we believe you have submitted data in error, or that you have not submitted it in a timely way, we will contact you and either ask you to provide further evidence to support the data or require you to correct any error as soon as possible. This will typically be following the R06 or R10 ILR data returns, which are key census points. If you fail to respond appropriately to any request or subsequent request, we may need to act according to the terms of your funding agreement with us.

Once the R14 ILR submission window closes along with the final funding claim, we will use this data for recovering any funding overclaim resulting from data errors in your final return(s). We may contact you to undertake further assurance and confirm any error value before we complete other processes, such as issuing reconciliation statements:

  • for provision funded through a grant, we will record this value as an adjustment against your reconciliation statement. We will record provisional error values for your year-end funding reconciliation statement to alert you to any potential impact on your final position at R14 – although the provisional amount is likely to change at the end of the year as you continue to add and change various data
  • for provision funded through a contract for service, we will offset this value against future delivery

How we will share data with you

We will share our findings through the post-16 monitoring dashboard, which you can access via view your education data. Usually, the first dashboard each year will be from December (following the close of R04 ILR data submission), and we will publish each month thereafter, once the ILR submission window closes and we have quality assured the data. We have indicated when we expect to publish each month on the landing page of the dashboard.

To access the dashboard, you will need a DfE sign-in account that enables you to access multiple organisations from one account. Once successfully logged in, you will have the option to select ‘data quality assurance’, following which you should see a link to the ‘post-16 monitoring reports dashboard’ and you click on ‘dashboard’.

We expect you to use the dashboard as part of your routine data quality and submission cycles to proactively review the data and evidence you hold, ensuring they reflect each other and are correct for the relevant funding rules. We recommend submitting data earlier than R04 as this will support you to identify any errors early and to correct them at R04 (which is the data used to calculate your next year’s funding allocation).

The dashboard will show funding values so that you are aware of the potential funding impact if you have not corrected errors by year-end. This funding varies depending on the relevant methodology and includes the following:

  • aim level year-to-date earnings for adult skills fund (ASF) provision
  • learner level funding for 16 to 19 provision
  • aim level SLC payments data for advanced learner loans
  • levy/non-levy payments data for apprenticeships

We share devolved ASF data with the relevant combined authorities.

Summary of changes since last year

We have refocused our offer this year in line with ESFA’s overall risk appetite and assurance approach, and in response to the new ASF, which replaces the adult education budget (AEB) for starts from 1 August 2024. Data will also be available through tools such as the provider data self-assessment toolkit and subject to our audit regime.

We have added one new report this year called ‘FRM72 – Changes to actual end date and/or planned end date after R14 of previous year’. We have removed these 8 reports from last year:

  • FRM16 – Learners who have achieved a full level 2 qualification (or higher) and are fully funded for a further level 2 entitlement aim
  • FRM17 – Learners who have achieved a full level 3 qualification (or higher) and are subsequently fully or co-funded for a further level 3 entitlement or adult offer aim
  • FRM19 – Traineeships where the learner has already achieved an apprenticeship or a level 4 qualification and above
  • FRM28 – Planned hours for students who start in-year and complete or leave learning within their initial 6-week period
  • FRM29 – Students who complete or leave learning on or just after the qualifying period for funding
  • FRM38 – Learners undertaking English and/or maths within AEB when they have already achieved their legal entitlement
  • FRM43 – 16 to 19 study programme students on qualifications with no planned learning hours
  • FRM65 – T Level industry placements below the minimum hours for the specialism

Report details

This section explains each of the reports in more detail. For each report, we cover any changes from last year’s report, the funding streams it covers, the purpose of the report, what action you need to take and what action we will take.

FRM01 – Learners repeating a previously achieved learning aim

Changes from previous funding year

None

Funding streams reviewed

  • ASF
  • apprenticeships

Summary

We will not fund a learner to repeat the same regulated qualification where they have previously achieved it – we have excluded exceptions for English and maths and GCSEs where the learner has not achieved grade 4 or above. We will fund a learner assessed as having an existing skill level lower than grade 4 (even if they have previously achieved a GCSE or equivalent qualification in English or maths). For apprenticeships you must account for prior learning and experience when negotiating a price with the employer and reduce the content, duration and price accordingly.

What you need to do

You must code aims which are not eligible for funding as funding model code 99 (Non-funded (No ESFA funding for this learning aim)). If the aim is continuing from a previous year, you will need to follow the provider support manual guidance on correcting aims with an incorrect funding model after the R14 hard close submission. For apprenticeships, you may need to review/renegotiate the price and ensure that minimum duration requirements can still be met.

What we will do

We will recover any funding overclaim for errors that remain in your R14 data return.

FRM06 – Continuing learners from last academic year who do not appear in this year’s ILR

Changes from previous funding year

None

Funding streams reviewed

  • 16 to 19 study programmes
  • advanced learner loans
  • apprenticeships
  • ASF
  • T Levels

Summary

Your current year’s ILR must include any learning aims that were reported as continuing (completion status 1 – the learner is continuing or intending to continue the learning activities leading to the learning aim) in the previous year’s final ILR return, even if the actual end date is in the previous funding year. Failure to report timely and accurate withdrawals data in your previous year’s R14 return may have resulted in a funding overclaim and could also impact the calculation of qualification achievement rates.

What you need to do

You must report this data to us. You must report all withdrawals within 3 months of the learner finishing and by the final collection of the funding year.

What we will do

We may contact you in-year to understand the reasons for this data error and ensure data is reported accurately. If correcting this data triggers FRM27, then we will recover any funding overclaim from that report for errors that remain in your R14 data return.

FRM13 – Learners undertaking English and/or maths within an apprenticeship when they have already achieved level 1 or above

Changes from previous funding year

None

Funding streams reviewed

  • apprenticeships

Summary

We will fund an apprentice to achieve up to an approved level 2 qualification in English and maths where they do not already hold a suitable equivalent qualification. Where the apprentice already holds approved level 1 qualifications, they must start, continue to study and take the assessments for a level 2 English and/or maths. Our latest rules confirm that apprentices holding GCSE grade D to G/3 to 1 have met the level 1 requirement so are ineligible for further funding at entry or level 1.

What you need to do

You must recode the aims with funding model code 99 (Non-funded (No ESFA funding for this learning aim)) or follow the provider support manual guidance on correcting data errors after the R14 hard close submission of the previous year (aims with an incorrect funding model).

What we will do

We will recover any funding overclaim for errors that remain in your R14 data return.

FRM20 – Loans learning not being recorded in ILR

Changes from previous funding year

None

Funding streams reviewed

  • advanced learner loans

Summary

You must accurately complete all ILR fields for loans-funded learners and make ILR returns as required in the ILR specification and the provider support manual.

What you need to do

If the learner has passed the initial liability point for provision funded through an approved loan, you must ensure that you have recorded the aim with funding model code 99 (Non-funded (No ESFA funding for this learning aim)) and the advanced learner loans indicator (Learning delivery funding and monitoring (FAM) type ADL, FAM code 1 – Aim is financed by an advanced learner loan). You must not record a source of funding for this provision.

What we will do

Where your data does not support the funding that you have received from SLC or claimed from the loan’s bursary, we will take action to get this corrected and could recover funds or require you to make repayments to SLC.

FRM27 – Continuing or completed learning aims that are now reported as withdrawn on or before 31 July of the previous funding year

Changes from previous funding year

None

Funding streams reviewed

  • advanced learner loans
  • apprenticeships
  • ASF

Summary

If a learner is continuing learning at the final R14 collection at the end of the year, but you record in the subsequent ILR year that they should have left in the previous ILR year, you may have earned funding that you need to repay. This report is to give notice of potential clawback for any overclaim resulting from late reporting of the data. If the error extends into multiple previous years, the recovery could exceed the amount shown as we only show the previous year’s funding.

What you need to do

You can calculate and repay the overclaim in-year through EAS, recording a negative figure in the ‘authorised claims’ adjustment type. You do not need our permission to use this adjustment type to pay back funding. However, please let us know the details behind the adjustments you are repaying funding for by contacting our Customer Help Portal, selecting the ‘DfE/ESFA returns and data requests’ option. The ESFA funded adult skills fund: funding rates and formula provides further guidance on this – see ‘recording late data in the ILR’.

What we will do

We will recover any funding overclaim for errors that remain in your R14 data return once we have confirmed any adjustments reported through EAS. As this error will relate to previous funding years, we will not process this recovery through final claims and reconciliation processes for the current year, but we will account for previous year’s reconciliation processes.

FRM30 – Students with more than 40 planned hours a week

Changes from previous funding year

None

Funding streams reviewed

  • 16 to 19 study programmes
  • T Levels

Summary

The number of hours a student may study should not be greater than the legal maximum of 40 hours per week and both the study programme’s planned hours and planned dates will need to reflect this. For students on 16 to 19 study programmes spanning more than one funding year, the planned hours recorded must be set at the start of each funding year to only reflect the planned hours for that funding year.

For students on T Level programmes, the total planned hours (for the 2-year duration) must be recorded in the data return at the start of their programme. The total hours must be reported in both years 1 and 2 to retain the correct funding band.

What you need to do

You must adjust the planned learning hours to ensure that the student is not studying more than 40 hours per week and both the study programme’s planned hours and dates reflect this. Planned learning hours must be realistic and deliverable and supported by auditable evidence that the activity is timetabled and exists.

What we will do

We may contact you in-year to ensure data is reported accurately.

FRM37 – Apprenticeship off-the-job training hours below the minimum

Changes from previous funding year

None

Funding streams reviewed

  • apprenticeships

Summary

The minimum policy requirements are outlined in the apprenticeship funding rules – English and maths training does not count towards this. We have calculated this value in line with the methodology described in the off-the-job training guide and calculator tool. This report is based on ILR data only and should be viewed alongside any data you have reported in the apprenticeship service to capture any reduction in off-the-job training time or duration due to recognition of prior learning.

What you need to do

You must follow the minimum policy requirements that are outlined in the apprenticeship funding rules, correcting any data errors to ensure the apprentice is eligible to be undertaking the apprenticeship and has undertaken the correct amount of off the job training by the end of the apprenticeship practical period.

What we will do

This data supports the apprenticeship training provider accountability framework, and we may contact you in-year to request further evidence and ensure your data is correct and apprentices are eligible for government funding.

FRM56 – 16 to 19 study programmes with planned learning hours but no regulated qualifications

Changes from previous funding year

None

Funding streams reviewed

  • 16 to 19 study programmes

Summary

Timetabled hours for non-qualification activity should be recorded in the planned employability, enrichment and pastoral hours field. We expect that, for most learners, non-qualification activity will support, and form part of, a structured programme of learning that includes qualifications.

What you need to do

If you are not delivering any qualification hours, you must report the planned learning hours field as 0. Non-qualification learning aims should be recorded in the planned employability, enrichment and pastoral hours field. You must be able to evidence that a proportional cost has been incurred in delivering this activity and be prepared to demonstrate how it supports progression to further levels of study or employment.

What we will do

We may contact you in-year to understand the reasons for this data error and ensure data is reported accurately. We may ask to review evidence of cost and need and how value can be demonstrated.

FRM69 – Proportion of planned employment, enrichment and pastoral (EEP) hours is 50% or more of total planned hours

Changes from previous funding year

None

Funding streams reviewed

  • 16 to 19 study programmes

Summary

We expect most students to be undertaking qualifications-based programmes that support development and progression in line with their career plans – we have excluded students who have self-declared any learner learning difficulties, disabilities (LLDD) or health problems or have been reported as requiring additional support. You must be able to evidence that a proportional cost has been incurred in delivering this activity and be prepared to demonstrate how it supports progression to further levels of study or employment.

What you need to do

You must ensure that you have correctly recorded planned learning hours for any qualifications being delivered and recorded non-qualification delivery as EEP.

What we will do

We may ask to review evidence of cost and need in-year to ensure that data is accurate, and value can be demonstrated. Your risk of audit will increase where EEP exceeds 50% of study programme hours.

FRM71 – Planned hours for continuing students who complete or leave learning within 6 weeks of 6 September

Changes from previous funding year

None

Funding streams reviewed

  • 16 to 19 study programmes
  • T Levels

Summary

You must calculate the planned learning hours for a student’s study programme when they are first enrolled. For students continuing study programmes after the summer break, the planned hours recorded must be set at the start of each funding year to only reflect the planned hours for that funding year. For T Level programmes, the planned learning hours for the 2-year programme must be recorded in both years. You must update the planned learning hours if they withdraw from any (or all) learning aims within the first 6 weeks of attendance.

What you need to do

When a student withdraws from one or more aims within the first 6 weeks of a programme, you must update the planned hours for such aims from the total. This rule applies regardless of the original length of the study programme or the funding band. If excluding the hours already delivered within the first 6 weeks would make a material difference to the funding band you can include the hours already delivered in the planned hours.

What we will do

We may contact you in-year to ensure data is reported accurately.

FRM72 – Changes to actual end date and/or planned end date after R14 of previous year

Changes from previous funding year

New report

Funding streams reviewed

  • advanced learner loans
  • apprenticeships
  • ASF

Summary

The learning planned end date must remain the same between teaching years. It can only be amended outside of the qualifying period within the first ILR year, and only to correct administrative errors – it cannot be revised to account to cover scenarios such as slow progress or illness.

If a learning actual end date was recorded in the previous year’s R14 file and the aim continues to be returned in the current year, then the learning actual end date must not be changed.

For apprenticeship standards on a programme aim, the learning actual end date must not be changed once the end-point assessment period has been completed. Once the end-point assessment has been completed, you record this date in the achievement date field, regardless of the outcome.

What you need to do

Change to actual end date between years

You must re-instate the actual end date that was recorded at R14. If the learner completed learning, but failed the assessment, any new learning being delivered to achieve the qualification must be reported as a new learning aim record. Where a learner has returned from a break in learning, you should create a new aim. If the learner is continuing in learning, and the end date was reported in error, you need to change the completion status to code 6 (learner has temporarily withdrawn from the aim due to an agreed break in learning), report a new instance of the aim and record the restart indicator. See the provider support manual section 5 for more details on doing this correctly.

Change to planned end date after R14

You must re-instate the planned end date that was recorded at R14. Where learning is continuing into this academic year, set the completion status to code 3 (the learner has withdrawn from the learning activities leading to the learning aim) and complete the withdrawal reason using code 40 (learner has transferred to a new learning aim with the same provider) and record a learning actual end date of 1 August of the current year. See the provider support manual section 5 for more details on doing this correctly.

What we will do

We will recover any funding overclaim for errors that remain in your R14 data return.

Other areas that we are monitoring internally

We will also monitor some areas internally to support the development of future systems and policy, and to identify specific scenarios that may be covered by an external report in the future. This includes reviewing any funding claims you submit, including your EAS, to ensure they are accurate and represent value for money. We may contact you to better understand data, and if we identify any behaviour that indicates a potential funding risk.

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