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ESFA Apprenticeship Audit: Common Errors and how to Avoid Them
December 10, 2019
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A Tribal Group Blog by Carla Martinho

On 11th June 2019 the Education and Skills Funding Agency (ESFA) published the snappily titled “Common findings from funding assurance work on post-16 providers and institutions” guidance document. It summarises the findings from the agency’s annual programme of assurance visits (in other words, audits) of providers delivering:

ESFA apprenticeship audit: common errors and how to avoid them
  • 16 to 19 study programmes
  • apprenticeships
  • adult education budget (AEB)
  • Advanced Learner Loans

For apprenticeships, there were no real surprises contained in the guidance if you have been working closely with the sector since the reforms were implemented (or more accurately started).

Here’s a summary of the key findings relevant to apprenticeships and some tips for avoiding them to ensure a smooth and successful audit:

1. Recognition of prior learning

Some providers have failed to reduce the funding claimed for learners who have relevant prior learning. The ESFA has even introduced a new report in the Provider Data Self-Assessment Tool (PDSAT) to help providers understand where they may have failed to reduce the price – and to allow the Agency to monitor provider data on this too of course.

Top tip: If you aren’t checking your ILR data using the PDSAT every month, start now. And if all of your apprenticeships are charged at the same rate for all learners, then the likelihood is that you have an issue and need to review who should have their funding reduced because of prior learning or experience.

2. Ineligible costs

You can’t calculate how to reduce the funding for RPL if you don’t have a model of how the costs of the apprenticeship have been calculated in the first place using eligible costs only.

Top tip: Create a template for calculating the cost of every apprenticeship standard or framework you deliver and check this against the eligible costs in the funding rules. Use this baseline model of costing to justify your Total Negotiated Price (TNP) price and amend this baseline to evidence reduction of price tailored for each learner who has RPL.

3. Minimum duration

This is one of the easiest rules to comply with and yet according to the recent findings, it’s one of the most common – and potentially most costly – errors! If this condition is not met, the whole apprenticeship for that learner will be ineligible for funding.

Top tip: As well as checking that all your apprenticeships meet the minimum duration rules, double-check that reducing the content of the apprenticeship to account for RPL doesn’t take the length of the apprenticeship below the minimum duration.

4. Off-the-job training

This is another one essential for funding, and if this condition is not met, the whole apprenticeship for that learner is ineligible for funding.

Top tip: Like the top tip for eligible costs, create a template for modelling how off-the-job training will be delivered for every framework or standard during the given duration. Then tailor it for every apprentice who has the content reduced due to RPL. Evidence of actual off-the-job training needs to be recorded for every learner and needs to evidence that it matches the model.

Check that 20% off-the-job has actually been delivered before completion and/or end point assessment.

5. Commitment statement and apprenticeship agreement

The information recorded on the commitment statement must reconcile with the apprenticeship agreement and the ILR. The absence of this evidence may result in a funding error.

Top tip: This isn’t just an induction process – you may need to update all three documents with relevant changes in circumstances such as breaks in learning, changes of job title, pathway or standard.

6. Learning start, learner status, learning end dates

This one is as old as the hills and sounds very simple, yet so many providers get caught out by it. Basically, if you are claiming funding for a learner starting their apprenticeship, you need to have evidence that they have started learning – not just been enrolled, inducted or started a new job. You need evidence that they have to have started learning activity related to the content of their apprenticeship.

Once they have started, if an apprentice is noted on your ILR as in learning, you need to be able to evidence at audit that they are undertaking learning on an ongoing basis. Again, don’t assume that attendance at work or college is evidence of learning, unless you can prove that they were there doing learning activity which forms part of their apprenticeship.

If a learner takes a break in learning or they withdraw from their apprenticeship you must be able to evidence learning up to the withdrawal date. If you can’t then you should change the withdrawal date to correspond with the last piece of learning evidence you have, even if that means drawing down less funding. With work-based learning particularly it’s very easy to get caught out because learners often withdraw because of dismissal at the end of a lengthy disciplinary process during which the learner is not engaged with learning. In that circumstance the end date on the ILR should be the last date of learning taking place and not the last date of employment.

Top tip: Review your learner list every month to check that they really are all in learning. This is where an eportfolio really comes into its own as you have an audit trail of learning taking place.

7. Employment status

Having stated at the start there were no surprises, I wasn’t expecting employment status to crop up in the findings. It’s simple – an apprenticeship is work-based learning; if the learner isn’t in employment, then they aren’t an apprentice and you can’t draw down funding for their learning.

Top tip: Don’t get caught out by signing up learners before their contract start date and using that as their enrolment date and the ILR learning start date (see also 2 above). It may only be a difference of a few days but they aren’t employed according to the funding rules.

8. Payment of employer contributions and small employer waiver

For delivery to non-Levy employers you need to evidence that you have invoiced the 10% contribution. For any employers where you are charging above the maximum funding cap, you also need to show that you have invoiced them for this difference.

Top tip: Invest in a student management system with good functionality around financial records and invoicing. For employers with 49 or fewer employees, make sure that you have a signed declaration from them before you deliver any learning.

9. English and maths

All learners who complete their level 1 English or maths should be offered the opportunity to study at level 2.

Top tip: Build this into your level 1 completion process. Could you hand out a letter with the certificate? You don’t just need to do it – you need to be able to evidence that it’s being done which can be difficult if none of your learners go on to study at level 2. 

These are my top tips to help you build audit preparation into your everyday delivery – but as always, they aren’t a substitute for reading the full document.

Ofsted Blog: What Ofsted Looks at When it Comes to Careers Education, Information, Advice and Guidance
March 21, 2019
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Julie Ashton, senior Her Majesty’s inspector, and Nigel Bragg, Her Majesty’s inspector, explain why good-quality careers guidance should be available to helpOfstedyoung people make informed decisions, and outline what Ofsted looks at in inspections when it comes to careers education.

Not so long ago, the career decisions we made as teenagers set us on a path that lasted until we received our free bus pass. For many, the days when we had a job for life are now long gone, yet it’s fair to say that the career decisions we make as young adults are still important.

We can all agree that careers guidance matters. Schools and colleges have a vital role in preparing pupils and young people for life beyond education, and that is not just limited to exam grades. Read more

How to do Well In the New Ofsted
February 13, 2019
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The following blog was posted

We invited Ofsted in to our school this week to support the pilot of the new framework, which will come into play in September. The framework is currently open for consultation, and you can find out more information here.

First up, I do need to give some context to this post. This is my own personal opinion and experience of the process. As a school and as a leadership team, we found the process to be a generally positive one, though one which was thorough and challenging. I am keen to emphasise, though, that follows is very much my own personal reflection, as AHT for Upper KS2 and the school’s Curriculum leader. It is also worth noting that is this was a two-day pilot inspection, the actual final framework may or may not differ from this experience.

I want to keep this as a brief and snappy post, so here we go.

We didn’t talk data; we really talked curriculum

Read more

Ofsted is Going Digital!
September 11, 2018
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This blog by Sean Harford will look at the way Ofsted inspects education, from early years to schools and the further education and skills sector. It will update you on developments and feature current issues.

I hope everyone enjoyed their summer holidays and that you are all now comfortably settling into the new academic year.

This is often a time for introducing fresh ways of doing things – including here at Ofsted. This autumn term our inspectors are starting to collect evidence on a digital platform, rather than recording all their notes using pen and paper.

We’ve developed a new electronic evidence gathering (EEG) tool, which will make the collection and sharing of inspection evidence much more efficient. Beginning this month, we will be gearing up to use this new tool on over 8,000 inspections annually.

As you probably know, inspectors currently capture evidence on handwritten forms. These forms are collated by the lead inspector and sent to our evidence collection centre, where they are scanned and stored electronically. Let’s be honest, this is all a little bit 20th century. So, in line with many other public sector organisations, we decided the time was right for Ofsted to embrace modern technology in ways that make the very best use of our resources. Read more

Blog by Ofsted Inspector Chris Jones, HMI, Specialist Adviser for Apprenticeships
August 15, 2018
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In the following blog Chris Jones HMI, Ofsted’s specialist adviser for apprenticeships, blogs about the changing framework, apprenticeship standards and how to record the progress that apprentices make.

The Institute for Apprenticeships is increasing the number of apprenticeship standards available to employers and apprentices.

These changes have been introduced alongside the apprenticeship levy. At present, when an apprenticeship standard isn’t available, apprentices complete the technical and vocational qualifications relevant to an apprenticeship framework

Now, a new model of apprenticeship is emerging and the structure is changing, as I wrote about in a previous blog. This approach is much more occupationally specific and is directly linked to the needs of employers.

Most apprenticeship standards don’t contain qualifications. They focus on the knowledge, skills and behaviours expected of the apprentices. An end-point assessment, specific to the apprenticeship standard, validates the standard.

Apprenticeship frameworks

We know that many frameworks will disappear in 2020. Apprenticeship standards will replace the frameworks as part of the apprenticeship reform programme. Most apprentices work at levels 2 and 3, with around 11% of apprentices working at level 4 and above. The proportion working at higher levels is increasing because over 40% of standards are for higher and degree level apprenticeships. For areas like business administration there is no replacement apprenticeship standard at level 2.

It’s clear from the range of frameworks that are still available, that many apprentices working at levels 2 and 3 will continue to work towards an apprenticeship framework for some time, and hence will continue to complete nationally recognised qualifications. Providers and inspectors can compare qualification achievement rates and look for patterns and changes to help them decide how well apprentices are doing.

Because most apprenticeship standards have no qualifications, inspectors and providers must be clear about the different ways of measuring achievement. As inspectors, we need to consider what these changes mean for inspection practice. Read more

Ofsted Blog: Building Confidence, Encouraging Aspiration
June 13, 2018
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Sean Harford blogs about how Ofsted assesses the effectiveness of careers guidance on offer.

As exam season comes to a close and results season approaches, many households around the country will be waiting for that slip of paper or email telling them how their young person did and what opportunities are now open to them. It’s an exciting couple of days and the breakfast broadcasts will be full of young people opening those envelopes live on air.

It’s the culmination of a lot of work. By the young person and of course, their teachers. But many organisations and support structures have also contributed to their success and provided advice for what comes next. Parents, local employers, higher education institutions and further education colleges, the Careers and Enterprise Company, the National Careers Service and many others have all played a part in supporting these young people to, hopefully, work hard and make the right decisions for their futures.  Part of Ofsted’s role is to assess the effectiveness of the careers guidance offered.

How we inspect careers guidance

We don’t have a preferred style of careers education, information, advice and guidance (CEIAG) for schools, colleges and other education providers we inspect. We do expect, as a standard, that young people will be offered CEIAG that includes guidance on their subject choices, discussion on their career aspirations and how they can achieve them and how they’re progressing towards this. Work experience and guidance on a vocational or academic path and routes post-16 whether those be A levels, training or vocational education should all be available. Read more

Blog by Ofsted Inspector Anita Pyrkotsch-Jones
May 31, 2018
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In the following blog Anita Pyrkotsch-Jones, Her Majesty’s Inspector and national lead for careers guidance and youth engagement, she describes on a four-day further education and skills inspection.

I’m a member of a seven-strong team on this inspection of a general further education college. We report to the lead inspector and inspect different aspects of the common inspection framework. This includes 16 to 19 study programmes and adult learning programmes.

I’m responsible for inspecting two key judgements: the quality of teaching, learning and assessment, and personal development, behaviour and welfare.

Initial team meeting

I’ve had my pre-inspection meeting and gathered all my background material. At the first team meeting, the lead inspector discusses inspection processes with us and the college nominee, who is a member of the senior management team, and we agree a timetable of activities. The principal gives a short presentation about the college and improvements made since the last inspection. Read more

Ofsted Assessment – What Are Inspectors Looking At?
April 24, 2018
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The following blog was written by Sean Harford, Ofsted’s National Director, Education since September 2015.

 

In a previous blog, I discussed data and how it must not be the be-all and end-all of an inspection. I want to build on that and talk about assessment.

There’s been a great deal of change, as you know, in assessment over the past few years. Rightly, the blunt instrument of levels has been removed and replaced by the freedom for different schools to develop assessment systems of their choosing. With this needs to come a move to a far more sophisticated way of thinking about how we assess pupils. And of course, what also comes is the need for sharper thinking about how assessment sits within the curriculum. I like Tim Oates’ remark about how good assessment is ‘an insight into the mental life of the children’.

When it comes to inspection, inspectors are looking to see that a school’s assessment system supports the pupils’ journeys through the curriculum. It’s really important that schools don’t design assessment around what they think inspectors will want to see.

I reiterate: inspectors do not need to see quantities of data, spreadsheets, graphs and charts on how children are performing. We don’t want to see a specific amount, frequency or type of marking. You know what’s right for your pupils and we trust you to design systems that reflect their achievement – the achievement that’s come about through the teaching within your curriculum. Read more