Whilst it is generally well understood that compliance with Education and Skills Funding Agency’s (ESFA) funding rules and requirements is fundamental to running a successful training provider or college, putting those rules into practice is not easy. Success depends on two factors: design and implementation.
Over the years, the Strategic Development Network (SDN) has worked with many providers on their compliance assurance activities and it is rare to find providers that do not, in the first instance, have errors in their data and evidence which may lead to under or over claiming funding. This is usually linked to systemic issues with the design of the evidence system or misunderstandings of funding rules or methodology as well as ability to confidently interpret and make evidence-based decisions on the grey areas of the funding rules.
Most education providers want to grow, and the introduction of T Levels and the growth of the level 3 free courses for jobs (previously the national skills fund) and traineeship provision are proving very popular. With the addition of any new programme comes additional funding rules and requirements and therefore additional need for all new compliance systems and processes – or does it?
Of course, each programme has its own individual rules and variations but there are consistencies in the foundations of a good evidence system.
The funding system is complex. The apprenticeship funding rules alone consist of 140 pages, not to mention the contract, Individualised Learner Record (ILR) specification, support manual, technical funding guide and other supporting documents. So, if you are a provider who delivers only apprenticeships, that is more than enough rules you need to be familiar with and ensure your system design and implementation complies with. For providers who deliver provision using Adult Education Budget (AEB), European Social Fund (ESF), loans, 16-18 and now T Levels funding, well, that’s at least another set of rules or guidance for each funding stream that you need to comply with.
The foundations of compliance though are the same:
We’re often asked how different the compliance requirements are for each of the funding streams – the answer is that whilst the details of the rules might be different there are similarities.
- • There will always be rules about which learners are eligible to be on the programme, for what, over what time etc.
• The programme design will be essential to how successful the learning journey is which impacts your long-term ability to deliver.
• Every learner needs to exist, be on programme and meet specific milestones to generate funding.
• Data accuracy of the journey is the final piece, how you communicate that journey to the funder usually through the ILR.
It is possible to think about compliance across all your funding streams and look to build in processes which can serve multiple needs making it much more efficient for you to operate.
No matter what funding rules you are having to follow it is important you take the time to fully understand them and design your systems and processes to meet them. You will also need to establish robust evidence collection systems and make plans for how you will monitor your implementation of systems and processes to ensure these are effective. Alongside with this however is the need for your people to understand the system you put in place.
Designing and implementing effective data, funding and compliance systems from the bottom up (using the rules) may seem like the most logical approach, however, if you already have systems and processes in place for another funding stream perhaps think about which systems, processes and mechanisms can be adapted. You really don’t need to start from scratch and create yet another, different system and process. Try to keep as much consistency as you can making it as simple as possible for you to manage but putting in place effective controls to make sure it works.
Need further support?
We have an in-depth webinar coming up in September go go through the apprenticeship funding rules for 2022 – 2023.
Led by SDN’s compliance specialist David Lockhart-Hawkins, the session will cover:
- The key changes and risks
- Data capture and the ILR