Guidance

Common findings from funding assurance work on post-16 education providers: 2024 to 2025 assurance year

Updated 30 September 2026

Applies to England

Overview

This document raises awareness of the common post-16 funding rules’ compliance issues identified from our assurance work on the 2024 to 2025 assurance programme. This will help providers:

• check their compliance with post-16 funding rules
• make improvements, where necessary, to ensure they are compliant

This guidance covers the common compliance issues for:

• 16 to 19 study provision
• apprenticeships
• adult education budget (AEB)
• advanced learner loans and loans bursary
• learning support and subcontracting

Who this report is for

This information is useful for senior leaders, managers and staff in:

• colleges, sixth forms and general further education settings
• agricultural and other specialist further education settings
• independent training providers
• higher education institutions
• academy trusts
• schools with sixth forms

It is also useful for:

• members of governing bodies and boards of providers
• local authorities funded by the Department for Education (DfE)
• auditors and advisors
• sector bodies including the Association of Colleges (AOC), the Sixth Form College Association (SFCA) and the Association of Employment and Learning Providers (AELP)

Our language

In this document we use:

• ‘providers’ to refer to colleges, independent training providers and higher education institutions
• ‘learners’ to refer to all learners, students and apprentices funded by DfE

Assurance work on post-16 funding claims

DfE is responsible for an annual programme of assurance work on post-16 funding claims, submitted by:

• further education (FE) and sixth-form colleges
• independent training providers (ITPs)
• higher education institutions
• education providers
• schools

The primary purpose of our work is to verify the completeness and accuracy of data provided in support of the funding claimed. DfE produces a range of documents that set out the funding rules for different funding streams. The section on funding rules guidance provides further information.

At the conclusion of each review, we send a report to the provider that sets out:

• the areas of non-compliance with the funding rules that were identified
• funding errors
• recommendations on how to address non-compliance

If funds have been incorrectly claimed, we will seek to recover the funding, including funding overclaimed in previous years. 

If funding or data errors are found, the provider needs to correct their learner data, so that funding adjustments can be made to payments, where appropriate.

If it is not possible to correct the learner data in the individualised learner record (ILR) and funding is at risk, funds are recovered by:

• offset from future payments
• invoice, if there are no future payments

Data accuracy: the ILR

The ILR is a learner level data return that publicly funded providers must collect and return at specific periods for each funding year.

It is the primary data sourced used by:

• DfE to make payments to providers
• auditors to reconcile against the evidence held by providers at learner level

Therefore, it is essential that the ILR reflects not only learner activity, but also the information and evidence held within the learner files.

We expect providers to:

• maintain ILR data and other learner documents properly and accurately
• keep evidence, as required by the funding rules
• record learner starts, withdrawals and breaks-in-learning promptly and accurately so that ILR data accurately reflects the providers’ learner population at any point in time
• regularly review their ILR data to make sure that only accurate ILRs that comply with the funding rules and follow the ILR guidance are submitted
• review the post-16 monitoring reports to make sure data returns and funding claims are correct

How to check your data

Providers should check their data each month.

Tools and resources to help check data are:

• how to provide and maintain accurate claims data
• provider data self-assessment toolkit (PDSAT) - to analyse ILR data and help providers identify and investigate potential anomalies in the data
• Financial assurance: monitoring post-16 funding for 2024 to 2025 has guidance on how to correct ILR data quality or funding errors

Many funding and data errors identified during assurance visits could be prevented if providers regularly review their learner data in post-16 monitoring reports for completeness and accuracy. Regular reviews throughout the year will also:

• prevent possible clawback of funding
• help providers have more certainty over funding

16 to 19 provision

Within the findings identified, the following areas related to significant overclaims in funds.

Planned hours

We check that the number of planned hours has been correctly recorded on the ILR and that there is evidence to support this.

Planned hours recorded incorrectly on the ILR is the cause of the majority of funding errors for 16 to 19 study provision. These errors may cause a funding overclaim or underclaim and can affect future allocations.

Most overclaims were found when:

• total planned learning hours did not match base documentation (including learning agreement, attendance records and timetable) - this also led to a significant volume of recommendations where funding was not impacted
• start date in ILR did not match base documentation
• total planned learning hours not reduced in the qualifying period, following completions or withdrawals
• summer starts not deemed eligible
• carry over programmes, if the total planned learning hours were not amended for the subsequent year

Other issues not leading to funding overclaims include:

• base documents not containing a detailed breakdown of total planned learning hours, or agreement by learner
• breaks included in total planned learning hours
• full level 2 or 3 total planned learning hours not demonstrated
• ineligible activity in total planned learning hours

Providers should make sure the correct planned hours are claimed by using:

• advice: funding regulations for post-16 provision
• 16 to 19 education: funding guidance 

Qualifying periods

We check that the learner has met the qualifying period, especially checking attendance if the learner withdrew shortly after the qualifying period.

There were instances where learners did not meet the start qualifying period for their programme of study because they had withdrawn within that period. Their evidenced last day of actual learning showed that they left before the end of the qualifying period. This resulted in a funding error where the full planned hours were claimed for the aims that were withdrawn.

Significant issues have also been identified with the quality of registers not clearly identifying learning start or actual end dates, in some cases requiring alternative evidence to provide assurance that the aim or programme met the qualifying period. In these instances, although no funding impact was identified, it created delays with the audit, impacting resource for all.

The start qualifying period is set at:

• 6 weeks for students with study programmes of 485 or more planned hours, or programmes of more than 24 weeks
• 2 weeks for all part time students below 485 planned hours whose programme is due to take between 2 weeks and 24 weeks

The funding rates and formula guidance has more information on the qualifying period.

Withdrawals

We check that:

• the learning end date recorded in the ILR reflects the last date that there is evidence of learning activity for each learning aim
• the completion status and planned hours have been recorded correctly

If learners withdraw from a learning aim within the first 42 days of the study programme, the remaining planned hours must be amended correctly. However, we identified a number of cases where the remaining planned hours had not been amended correctly, impacting funding.

There were instances where the ILR had not been updated with the withdrawal date, or the wrong date had been used, which did not reflect the last date of learning activity as evidenced by attendance records. Although these did not affect funding allocations, they informed a set of recommendations in the following areas:

• the use of generic actual end dates applied to all aims
• inaccurate actual end dates
• in-year late actual end date action
• programmes carried forward with late actual end date action
• registers did not clearly support actual end dates

Eligibility for funding

We check that the learner satisfies the eligibility criteria. This includes ensuring that the learner fulfils the requirements set out in the funding rules.

There were instances where the learner was deemed ineligible as they were over 19 with no additional evidence to support their continuing or education health care plan (EHCP) status.

Additional findings, which did not lead to eligibility concerns, resulted in recommendations in the following areas:

• inconsistent EHCP evidence
• general eligibility not evidenced effectively, including a significant volume for residency checks and controls
• learning agreement not signed or signed significantly after start

Within the findings identified, the following sub-sections relate to those with no overclaims, but that did result in significant volumes of non-compliance and recommendations. Although overclaims were not identified, there is a risk that future funding might be impacted.

Learning start date

We check that funding for a learning aim or programme has been claimed only from the date on which learning activity directly related to the learning aim or programme started and is evidenced.

There were instances where the start date was incorrect on the ILR, or there was no evidence of attendance. Examples of these include:

• a significant volume of incorrect learning start dates, impacting programme or aim
• no attendance for aim
• individual aims not clear on evidence
• learning aim did not have regular attendance evidence, by design, so learning evidence was on based work completed rather than active learning from the learning start date, up to the learning actual end date

Condition of funding

All providers delivering 16 to 19 study provision have to apply the condition of funding requirements set out in the funding rules to determine the requirement or exemption of studying English and maths.

If providers do not comply with these requirements, they may find that their lagged funding allocation is reduced in future years, if they breach published tolerance levels.

The main issues identified in respect of the condition of funding were:

• exemption codes recorded incorrectly or omitted from the ILR
• learners not undertaking an appropriate learning aim or enrolled onto a learning aim that they had already achieved
• a significant volume of inaccurate recording of the learner’s prior attainment level and grades
• documentation did not clearly define the exemption or required aim - in some cases, the initial assessment was not clear
• where learners were considered to be exempt, there was no evidence to support the exemptions

Work experience

We check relevant processes are followed when students are undertaking work experience as part of their programme.

We identified these issues in significant volumes:

• lack of reliable evidence to support learning start date, including no evidence of attendance
• inaccurate planned and actual end dates
• actual delivery hours not clear
• ineligible delivery hours, including travel and break hours
• location of work experience not clear or documented in the delivery location, including the use of generic postcodes
• incorrect codes used for internal and external work experience
• work placement aim missing from ILR or incorrect
• timetabling not clear, including assurance that the activity is planned, organised and supervised

Confirmation of learning agreement

The provider must retain original documents, including learning agreement (or enrolment form).

The learning agreement is required compliance evidence to support a funding claim. DfE uses it at audit to determine and cross-check key ILR data for the learner’s journey.

We identified these issues in significant volumes:

• agreement signed significantly after start
• learning agreement not in place
• full programme of aims not on agreement
• not signed by provider or learner, including amendments to original

The provider should use the funding regulations for post-16 provision, section ‘Learning agreement and enrolment forms’, as a checklist for requirements.

Apprenticeships

We found significant overclaims in funds in the following areas.

Negotiated price

We check that funds are being used for evidenced eligible costs and activities within the agreed price. We identified funding and control issues in documentation and costs relating to negotiated price.

Most overclaims were where:

• ineligible costs included in the price
• actual costs not being charged where the provider is the employer
• incorrect residual costs relating to a change of employer
• the agreed price relating to delivery or assessment costs in the supporting evidence did not match the ILR - there were significant instances of this

Other issues not leading to funding overclaims include:

• a significant volume of instances where the breakdown of costs for delivery and assessment was not demonstrated as agreed with the employer
• all of the total negotiated price returned in the delivery costs rather than split between delivery and assessment costs
• incorrect end-point assessment organisation, resulting in incorrect assessment costs
• subcontracting relationship and related costs not clear in contractual evidence

Learning activity and breaks-in-learning

We check the learner’s continued participation in learning, including English and maths by reviewing evidence of learning activity. 

Provider’s must have evidence that an apprentice is:

• involved in active learning, like off-the-job training or English and maths training, from the apprenticeship learning start date to the learning end date
• on a break-in-learning, if they are not in learning for a calendar month or more

For a break in learning, most overclaims where found when:

• final day in work used as learning actual end date
• break in learning not reported in the ILR or not actioned within a reasonable time
• learning start date of resumption not supported by learning activity
• learning actual end date not supported by learning activity
• monthly active learning not seen, or activity evidence not up to date - there were significant volumes of this instance

Other issues not leading to funding overclaims include:

• lack of evidence for intention to return
• paperwork for resumption not in full or completed timely, including training plan and apprenticeship agreement
• funding adjustment not applied for applicable aims
• active learning evidenced within a break in learning period on the ILR
• planned end date not extended on resumption
• following a break in learning, the original episode of learning had not been reported in the ILR

For a learning activity, most overclaims were when:

• active learning was not in each calendar month, as planned - there was a significant volume of these instances
• there was insufficient or no evidence of learning
• the learning actual end date was not returned, or was inaccurate, and did not indicate the learner’s withdrawn status

Other issues not leading to funding overclaims include:

• a significant volume of instances where the evidence was not reliable, or there were issues with the retention or completeness of evidence
• learner had achieved or was in gateway but was still recorded as in learning

Learning start dates

We check that funding has been claimed only from the date on which learning activity, funded by the apprenticeship budget, begins, and is evidenced. It can include off-the-job training and English and maths.

Common funding errors identified were:

• start date is not supported by evidence of learning activity - there were a significant volume of instances of this
• no evidence of learning
• functional skills learning were embedded so that the key learning dates were not clear

Where incorrect start dates result in a potential funding error and the learner is still in learning, this can be rectified by an ILR adjustment. Where the learner has withdrawn, funding will be recovered as monthly payments are likely to have been claimed in error.

Use the apprenticeship funding rules for guidance on learning activity. Funding can only be claimed from the date on which learning activity that is directly related to the apprenticeship and documented in the training plan, starts and can be evidenced.

Contractual arrangements - end-point assessment costs

We also check that the:

• total negotiated price (TNP) for the end-point assessment organisation (TNP2) is correct
• provider has entered a known or agreed cost, rather than an estimate

TNP2 is funding to allow the provider to make a payment to the end-point assessment organisation for a learner. We have found a significant volume of instances where the TNP2 value is not accurate. Where it is higher than the actual or agreed cost, this results in a funding error for the difference. This is usually because the provider has decided to use an estimate rather than the actual cost. We have also found that the TNP2 values are lower than the actual or agreed cost, resulting in recommendations to cleanse data and improve controls.

Providers must:

• retain evidence to confirm how the total negotiated price for delivery is calculated for each learner
• include a breakdown of the total negotiated price

It must be clear that only eligible costs have been included, and costs related to end-point assessment are not included.

Ineligible costs included in the total price will give rise to a funding error. Use the paying for an apprenticeship and eligible and ineligible costs in the apprenticeship funding rules for more information.

Other issues not leading to funding overclaims include:

• unsigned or no written agreement or agreed breakdown, to determine accurate end-point assessment organisations and price
• incorrect or incomplete end-point assessment organisations reference in the ILR

Knowledge, skills and behaviours - outcome

Provider’s must complete an assessment of the learner’s knowledge, skills and behaviours prior to the start of the programme, and depending on their age, the process varies.

Where the assessment is missing or lacks information or has been inaccurately evaluated, we may be unable to confirm that the total negotiated price and funding is correct.

Most overclaims were where:

• reductions to cost were not applied accurately
• recognition of prior learning was not recognised in skills scan outcome
• funding adjustments for functional skills were not applied accurately

Other issues not leading to funding overclaims include:

• a significant volume of instances where no or insufficient outcome is recorded for the initial assessment
• a significant volume of instances where providers were unable to demonstrate agreement with employer
• recognition of prior learning not correctly reflected in terms of content on training plan
• content and cost reduced although not needed. Providers did not effectively review the result of skills scan with learner and employer - this resulted in significant underclaims of funding
• high self-declared skill scan scores or prior attainment not validated for accuracy, impacting interpretation of content and cost

No evidence or inaccurate evaluation of initial assessment may result in a funding error, with potentially a full recovery from the start of learning. This is because we do not know if the learner is eligible after recognition of prior learning, or on the correct programme, especially where they have already achieved or withdrawn. Retrospective evidence can be considered for learners.

The apprenticeship funding rules has information on programme eligibility and recognised prior learning. The ILR provider support manual has support on ‘Funding adjustment for prior learning and other funding adjustments’.

Completion of practical period or programme

We test that:

• the actual off-the-job meets the eligibility and minimum requirements and that the underlying evidence supports the ILR
• where the volume of actual off-the-job training is less than planned, that there is a statement on file to explain the difference
• the completion payment is supported by evidence of completion of end-point assessment and supported by evidence of achievement and outcome
• evidence that the minimum duration requirement has been met
• where applicable, evidence that the total employer’s co-investment has been collected and recorded

Most overclaims were where:

• full employer co-investment was not collected
• minimum off-the-job training was not met
• inappropriate use of completion and outcome, where the completion payment was released in error

Other issues not leading to funding overclaims include:

• a significant volume of instances where there were unclear or incomplete off-the-job records
• off-the-job completed after the actual end date
• actual off-the-job value incorrect in the ILR
• completion and outcome status not returned for learners in gateway or complete

We will always try to resolve funding implications and seek alternative evidence, as these can be definitive in terms of error. However, finding these issues at audit invariably causes significant delays to the audit. Providers should ensure robust controls are in place prior to gateway to ensure these issues are mitigated or managed.

Learning actual end date

We check that the learning actual end dates reflect the last date of learning activity, where a learner has taken a break in learning or has withdrawn.

Most overclaims were where:

• incorrect or omitted learning actual end dates were applied for breaks in learning or withdrawals (the date did not reflect evidence of the last day in learning) - there were a significant volume of instances of no or unreliable evidence of learning

Other issues not leading to funding overclaims include:

• a significant volume of instances where there were incorrect or omitted learning actual end dates, but there is evidence of achievement, mitigating the funding error
• a significant volume of instances where gateway assessment or end-point assessment dates were used as learning actual end dates

These can result in a funding error for the time from the learner’s last learning activity for any of the funded learning aims. We seek to recover funding where an overpayment has occurred.

Use the apprenticeship funding rules and the provider support manual for help with recording information about:

• active learning
• learning end dates
• learner absence or withdrawal

Eligibility for funding

We check that the learner satisfies the eligibility criteria. This includes ensuring that the learner fulfils the following requirements set out in the apprenticeship funding rules:

• residency
• age
• employment status
• right to work

Most overclaims were where:

• learners were enrolled to multiple programmes or providers
• there was no evidence file
• learners had insufficient length of time for right to work

Other issues not leading to funding overclaims include:

• a significant volume of instances where control weakness was apparent in checking and documenting what evidence was seen for residency and right to work, as well as other requirements
• document signed after start

Make sure you refer to the apprenticeship funding rules in respect of learner eligibility and the evidence requirements to support this.

Within the findings identified, the following sub-sections relate to those with no or limited overclaims but did result in significant volumes of non-compliance and recommendations. Although overclaims may not have been identified, the risk is that funding impacts might develop.

Off-the-job training – calculation, plan and delivery

Off-the-job training (OTJT) was the main cause of apprenticeships funding errors, audit delays and control recommendations. All apprentices must spend at least 20% of their normal working hours (capped at 30 hours per week from 2022 to 2023, unless part time) engaged in off-the-job training. We check that the calculation of OTJT is correct, OTJT is planned and there is evidence of delivery.

The assurance reviews have identified a high volume of issues in relation to the planning and calculation of OTJT hours. These included:

• minimum OTJT not returned in ILR, either due to not being planned effectively or data quality. Providers can use PDSAT A-215 to determine many of this instances
• total planned OTJT being inconsistent between documents and the ILR. This invariably led to the requirement of updated document, delaying the audit 
• incorrect OTJT calculations
• OTJT plan either not in place or in full at start, insufficient to meet the minimum requirement, not clearly planned and defining what the activity is and when it takes place, or ineligible activity included in the plan

When reviewing OTJT delivery we identified a high volume of issues, including:

• missing OTJT, including insufficient progress; leading to instances of funding errors
• a significant volume of ineligible activity
• no OTJT records
• lack of verification by learner, leading to reliability issues
• start date evidence inferring enrolment, induction or initial assessment
• learners aiming for incorrect OTJT targets
• a significant volume of learning activity and link to apprenticeship content not clear
• a significant volume of dates and times missing, in many instances leading to assurance issues that OTJT are completed within working hours
• a significant volume where working hours not clear as OTJT records possibly contradict working day and breaks
• a significant volume where bulk hours are declared with insufficient context of eligibility
• hours prior to start not being eligible
• duplicate data and dates

OTJT is a legal requirement of an apprenticeship and an essential criterion for funding. If this condition is not met, there is a risk that the whole apprenticeship for that learner is ineligible and, therefore, all funds paid in respect of that learner are at risk.

Consequently, it is important that providers comply with the OTJT requirements, including evidence requirements, set out in the apprenticeship funding rules. Providers should also refer to the apprenticeships off-the-job training guidance.

Apprenticeship agreement and training plan

We check that there is a valid apprenticeship agreement and training plan for all learners. Many issues were identified in this area. Non-compliance with the funding rules included:

• a significant volume of incomplete training plans and apprenticeship agreements where they did not meet all requirements - or were combined, which led to instances of funding errors
• a significant volume where details within the apprenticeship agreement did not match the ILR or the training plan and visa versa
• the apprenticeship agreement or training plan was not fully completed or signed prior to start
• the agreement or training plan was not updated after a break in learning or change in circumstances, or if it was updated, on some occasions, it had not been signed to confirm changes
• a significant volume where signatures were not robust enough to protect the authenticity and security of the signature due to being typed, cut and pasted, or being editable or removable
• learners did not have an apprenticeship agreement for actual duration

• in the training plan, activities were not clearly defined, including at a learner, employer and provider level - relevant content was not always clear, including:

  • documenting exempt content
  • inconsistencies in off-the-job hours (OTJH) between sources
  • ineligible activity was planned within the OTJH
  • planned OTJH was not insufficient to meet the minimum

If there is an incomplete or no apprenticeship agreement between the employer and apprentice, then this is classed as an ineligible apprenticeship and all funds for that learner may be at risk. We can work with providers to rectify this in most cases, but this issue can be avoided by providers establishing appropriate controls to ensure they have apprenticeship agreements for all apprentices at the start of training.

Where training plans are not of sufficient compliance, the provider will be expected obtain updated and signed versions for in-learning learners. This delays the audit fieldwork.

Providers should refer to the apprenticeship rules and the apprenticeship agreement: template. A template for the training plan is also available. The funding rule bullets can be used as a checklist for what is required as a minimum.

Knowledge, skills and behaviours - assessment

Many issues were identified, including:

• lack of evidence of an appropriate assessment to confirm the learner’s knowledge, skills, and behaviours before starting the apprenticeship - this led to instances of funding error
• initial assessments not demonstrated as conducted prior to start
• lack of demonstration that there was agreement between parties on the assessment
• skills scan not completed following transfer from another provider
• unclear that skills scan aligned with standard’s content
• skills scan, including prior attainment, assessment and rationale of possible reductions to content and cost not clear or full

No evidence of initial assessment may result in a funding error, with full recovery from the start of learning. This is because we do not know if the learner is eligible after recognition of prior learning, or on the correct programme, especially if they have already achieved or withdrawn. Retrospective evidence can be considered for continuing learners.

Where the assessment is missing or lacks information, we may be unable to confirm that the total negotiated price is correct. There have been instances where providers have had to retrospectively check the assessment or total negotiated price for a high number of learners and where funding has been recovered.

The apprenticeship funding rules has information on programme eligibility and recognised prior learning.

The ILR provider support manual has support on ‘Funding adjustment for prior learning and other funding adjustments’.

16- to 18- year old apprentice

We check that the apprentice’s date of birth confirms that they were aged 16, 17 or 18 when they started their apprenticeship and that payment has been made to the employer as per funding rules.

Most overclaims were when:

• payments were confirmed as not paid to the employer
• qualifying period was not met
• eligibility for enhanced funding code 2 has been incorrectly added to the ILR

Other issues not leading to funding overclaims include:

• a significant volume of instances where payments to the employer were not made within 30 days of payment to the provider
• issues with demonstrating payments effectively

We will provide an opportunity for the provider to pay the employer during the audit, but if this fails, we would recover any unpaid funds. It is good practice to seek employer bank details before the start of the programme, or the first scheduled payment, as this helps prevent payment delay or failure.

Gateway assessment

We check records and evidence of end-point assessment completion and the end-point assessment requirements, along with evidence that the learner is still employed upon completion of the end-point assessment.

Most overclaims were found when it the ILR contained incorrect completion statuses, where the learner was still in learning or withdrawn. If a learner does not complete all their end-point assessments, for example 1 out of 2, and withdraws, they should be regarded as a withdrawal (completion status 3).

Other issues not leading to funding overclaims include:

• a significant volume where confirmation of employed status was not clear at and during gateway
• missing paperwork
• refutable signatures on compliance documents

Payment of employer co-investment

We check for evidence that employer co-investment payments for funded apprenticeships match the ILR.

Many issues were identified in this area. Non-compliance with the funding rules included:

• not collected as agreed in employer contract
• collected, although small employer; including where the small employer indicator was not returned
• reimbursement not applied following withdrawal
• records erroneously returned in ILR; either records not returned in ILR following payment or records returned in ILR where payment is not evidenced
• levy status was unclear within documents and conflicted with other sources

We will provide additional time for providers to mitigate funding overclaims during the audit, but this action is a cause of delay at fieldwork. Where the provider does not or cannot collect the employer co-investment, they are at risk of not receiving the completion payment.

English and maths

We check that the apprentice has been assessed to see whether they have English and maths exemptions.

If learners have an exemption, the provider must stop payments immediately.

Funding errors may occur if payments have been made in error because apprentices:

• are taking English and maths functional skills, but hold an exemption
• do not have an exemption but are not taking English and maths functional skills
• cannot demonstrate learning activity from start date

Many issues were identified in this area. Non-compliance with the funding rules included:

• a significant volume where the learner file or the Learning Record Service demonstrated they had prior attainment, leading to funding errors and inadequate initial assessments
• key learning dates were not accurate, leading to funding errors
• no learning evidence, leading to funding errors
• funding adjustments were not applied, or were inaccurate, leading to funding errors
• a significant volume of instances where exemption evidence was not collected or understood at start
• a significant volume of instances where aims were not returned in the ILR or effectively planned
• UK comparison was not made against the provided evidence

We recognise that there are times when the provider has acted in good faith by putting learners forward for their functional skills because the learner:

• has not declared prior attainment
• did not have proof of prior attainment

However, providers should have a robust process to show they have tried to ascertain the learner’s prior attainment.

Use the apprenticeship rules for support with recognised prior learning and English and maths.

Adult education budget  (AEB)

This section relates to the AEB. Lessons learned from these findings can be applied to the adult skills fund (ASF) for future years. Within the findings identified, the following areas relate to those with significant overclaims in funds.

Eligibility for funding

We check that the learner satisfies the eligibility criteria. This will include ensuring that the learner fulfils the residency requirements as set out in the rules.

Most overclaims were where:

• initial assessments were not conducted for such aims as Essential Digital Skills
• enrolment documents not clear
• under 19 incorrectly applied to this funding model
• eligibility not confirmed by provider - there were a significant volume of instances of this
• learner had already achieved their legal entitlement
• a combined authority, so not eligible for funding

Other issues not leading to funding overclaims include:

• a significant volume of weak controls at start and unsigned enrolments, impacting assurance on multiple eligibility confirmations
• initial assessments not conducted

Make sure you follow the rules for eligibility and the evidence pack requirements.

Prior attainment and initial assessment

This section relates to the prior achievement of qualifications, English and maths assessment and enrolled level, as well as identifying issues relating to the duplication and overlap in learning.

We check that any qualifications or other certificates already held, are taken into account when:

• establishing whether a learning aim can be funded
• establishing whether accreditation of prior learning applies
• calculating the proportion of funding remaining

Our testing found a number of errors in this area (as with apprenticeships programmes) relating to providers claiming funding without taking into account the learners’ attainment and study of prior qualifications. Where the proportion of funding has not been correctly calculated, we classify any overpaid funding as an error. 

We also test to ensure that the level on which the learner is enrolled for English and maths is correctly determined by the outcome of the initial assessment.

Most overclaims were where:

• initial assessments were not retained
• delivery at incorrect level, contradicting the initial assessment
• Learning Record Service or enrolment confirmed prior attainment
• delivery at multiple providers

Other issues not leading to funding overclaims include:

• prior learning not confirmed by provider; retrospective assessment of prior learning had to be taken
• a significant volume where the prior attainment code conflicted with Learning Record Service or enrolment
• no learner declaration of prior attainment

It is key for providers to complete a full and effective initial assessment before enrolment. As a minimum, this should include checks against:

• the Learner Record Service
• learner self-declarations
• a valid initial assessment programme to fulfil the requirements of the learner’s programme content

If we identify that no initial assessment is demonstrated and it cannot be resolved, incorrect enrolment levels, duplication or overlap in funding, we will recover all funds.

Use the AEB funding rules for more information on recognised prior learning and English and maths for those aged 19 and over.

Learning activity, including learning start and actual end dates

We check that funding claimed for the learner’s continued participation in learning is confirmed by evidence of learning activity from the start date of each aim up to the learning actual end date.

Most overclaims were where:

• the learning start date or learning actual end date in the ILR were not supported by evidence of learning activity - there were significant volumes of instances for this category, leading to significant funding errors
• there was no evidence of learning for the aim
• attendance evidence not clear or aim specific - there were significant volumes of instances of this
• changes to planned learning start
• incorrect completion status or actual end date; learning aim should be withdrawn or on a break in learning
• there were large gaps between on-programme payments

Other issues, not leading to funding overclaims include:

• a significant volume of instances with accuracy of key dates but completer not applied. These did not result in a funding error due to the correct completion status
• planned end date used for actual end date, including generic actual end date used
• attendance evidence not clear
• automated processes to determine key dates and completion statuses ineffective
• incorrect planned end dates, impacting payment profiles

Make sure you refer to the AEB funding rules  in respect of participation. The provider must update the ILR where planned learning does not take place This will mitigate the risk of error. Providers must ensure they have sufficient controls to check data on a regular basis to ensure accuracy.

Full and co-funding

We check that claims for full or co-funding are supported by:

• an assessment of the learner’s circumstances
• confirmation from the learner that they are eligible for a financial contribution from the government

Most overclaims were where:

• full funding code deemed incorrect due to no or incorrect assessment of eligibility criteria evidence, for example:

  • learners were not unemployed or not low wage
  • inappropriate benefits evidence
  • aim was not part of the legal entitlement or local flexibility or free courses for jobs did not apply
• learner already held a full level 2 or 3 and were not unemployed or in receipt of low wage
• unemployment is used as the eligibility criteria to claim full funding but there is insufficient evidence to support the eligibility criteria - this category contained a significant volume of non-compliance

Other issues not leading to funding overclaims include:

• documents were not clear on the rationale for full funding - there was a significant volume of this issue
• documents were not fully completed or confirmed by provider
• learners in receipt of low wage, or unemployed, had evidence that was not compliant or was missing
• evidence collection was out of date - for example, incorrect wage threshold on enrolment documents
• ILR learning delivery monitoring (LDM) or devolved area monitoring (DAM) codes incorrect

If the wrong level of funding is claimed, this will be classed as an error. We will make efforts to mitigate funding impacts by allowing time to obtain additional learner evidence, but this can be time consuming and create delays at audit fieldwork.

Use the AEB rules for more information on the criteria for full and co-funding, including the government contribution charts.

Delivery location

We check the accuracy and validity of the delivery location, to ensure accurate claims for uplifts to funding and that the postcodes have been returned accurately to confirm eligibility.

We identified a significant volume of instances where the generic postcode was used incorrectly in either of:

• a normal postcode was returned where the delivery was distance learning and the generic postcode was not used - this led to significant funding overclaims
• a generic postcode was used, but the delivery was not distance learning, potentially leading to underclaims of funding

Providers should use PDSATs to analyse and cleanse their data regularly and ensure data is up to date and accurate.

The following sub-sections relate to issues with no or fewer overclaims, but they did result in significant volumes of non-compliance and recommendations. Although overclaims may not have been identified, the risk is that funding might be impacted in future.

Learning aim achievement

We check achievement is correctly recorded in the ILR and is supported by evidence of achievement from the awarding organisation within 3 months.

The following was identified, resulting in funding errors:

• lack of or insufficient achievement evidence
• completion or outcome incorrect, resulting from inaccuracy, timeliness or inadequate evidence

Without the relevant evidence of completion and outcome status, achievement or completion payments may be at risk. We assess the payment profile based on learning activity and establish if funding needs to be recovered.

Advanced learner loans and loans bursary

The following areas gave rise to significant overclaims in funds.

Eligible for loans bursary funding

We check that a learner is eligible for loans bursary funding and that the correct monthly rate has been claimed.

Issue identified:

• no evidence of assessment or learning, resulting in all bursary funds in error

Make sure you use the advanced learner loans bursary and learner support sections of the advanced learner loans rules to ensure that claims are accurate.

Change of circumstances and transfers

We check that any change is accurately recorded in the ILR, and this matches the loans portal.

Issues identified include:

• incorrect completion status resulting in all bursary funds being recovered back to the last evidenced date of learning
• start date incorrect and not updated to actual start date following a change in the plan
• underlying documentation inconsistent

Entitlement to full funding

We check that learners aged 19 and above do not have an existing full level 3, or equivalent. qualification, and that they have waived their right to be fully funded.

Issues identified include:

• no evidence to demonstrate the learner waived their right to be fully funded - this led to funding errors where all funds are recovered
• incorrect prior attainment codes, leading to misleading data

The following sub-sections relate to issues with no overclaims, but a significant volume of non-compliance and recommendations. Although overclaims were not identified, the risk is that funding might be impacted in future.

Learning actual end date

We check that the learning actual end date recorded in the ILR and the loans portal reflect the date of completion, or the last date that there is evidence of learning activity for each learning aim.

We found a significant volume of incorrect or omitted dates, either identifying a withdrawal or completion of programme.

ILR consistent with loans portal and learning and funding information letter

We check that the Information in the learner file, returned to the DfE in the ILR, matches the data returned to the SLC via the loans portal, where applicable.

We check that the model learning and funding information letter is used to create the learner’s learning and funding information letter.

Issues not leading to funding overclaims include:

• incorrect key learning dates inconsistent between the SLC portal and ILR
• a significant volume of instances where the loans letter did not match DfE’s template, format or content
• inconsistent data between the loans letter and SLC portal

Further information is available on the advanced learner loans rules

Generic issues

Data quality and compliance - individualised learner record (ILR)

This section identifies the various inconsistencies within the ILR and evidence packs across all funded programmes.

For 16 to 19 provision, DfE uses the ILR to make payments to providers, so the ILR must reflect the evidence held on the:

• individual learning plan
• learner’s timetable
• provider’s attendance records

Providers must make sure that there is an accurate record of the learner’s journey.

The most common issues were:

• no learning agreement, or learning agreement incomplete
• learning aims missing or inaccurate
• total planned hours and the split between planned learning hours and planned employability, enrichment and pastoral (EEP) hours
• start and planned end dates
• actual end dates
• English and maths grades
• condition of funding coding for English and maths
• delivery location

Any changes or amendments should be recorded and evidenced in the appropriate documentation.

Providers should use the funding guidance for young people: ILR funding returns at Annex E to help them make accurate 16 to 19 funding data returns. This guidance gives the recommended minimum data checks that use both our funding monitoring reports and PDSATs.

For apprenticeship provision, government contributions, including additional payments are driven by the underlying ILR data. This must agree with information confirmed by the learner in the evidence pack. It is important that the data fields, used to match with apprenticeship service for funding purposes, are accurate.

The ILR is the primary data source for funding claims and ILR data accuracy is critical. There were large volumes of data errors found in providers’ ILRs, when reviewed alongside the evidence required to support that data.

This list is not exhaustive, but the main issues were:

• incorrect assessment price - these led to funding errors
• incorrect or omitted end-point assessment organisation references
• incorrect planned end dates - there were a significant volume of these and they affect funding by affecting the payment profile
• incorrect prior attainment codes - there were a significant volume of these
• incorrect delivery location postcodes or postcodes prior to enrolment - there were a significant volume of these
• omitted LDM 356 codes, indicating delivery to own employee
• incorrect or omitted total planned off-the-job or actual off-the-job - there were a significant volume of these
• incorrect or omitted completion and outcome statuses
• omitted aims

It is important that providers hold evidence that they are using apprenticeship funding appropriately and that the ILR data is correct. The apprenticeship funding rules list all evidence requirements. Most evidence will occur naturally from the normal business process. If evidence is not held, funds may be at risk.

Ensure that you refer to the apprenticeship funding rules, which provide details of the evidence required.

For adult education budget  provision, funding is driven by the underlying ILR data, which must agree with information confirmed by the learner in the evidence pack.

This list is not exhaustive, but the main issues were:

• employment status and codes, leading to funding errors
• postcodes prior to enrolment incorrect, leading to incorrect uplifts and resulting in overclaims or underclaims in funding
• incorrect National Insurance number - there were a significant volume of these
• incorrect key dates - there were a significant volume of these
• prior attainment code or date of birth was incorrect - there were a significant volume of these and this data provides insights to eligibility so this must be accurate
• enrolment forms were not fully complete, retained or were inaccurate - there were a significant volume of these

It is important that providers hold evidence that they are using adult education budget funding appropriately and that the ILR data is correct. The adult education budget funding rules list all evidence requirements. Most evidence will occur naturally from the normal business process. If evidence is not held, funds may be at risk.

For loans provision, the underlying ILR data must agree with information confirmed by the learner in the learner file.

This list is not exhaustive, but the main issues were:

• incorrect prior attainment code
• key learning dates and learning aims between various sources
• completion and outcome status not updated timely to show complete and achieved learning aims
• course fee between sources
• enrolment documents not fully complete or accurate
• delivery location postcodes incorrect

We recommend that providers fully utilise PDSATs to analyse and cleanse data. Many of the issues above can be mitigated and managed through a robust quality assurance process derived from and focussed around effective and regular use of PDSAT.

We share data reports with providers, which would identify issues through the post-16 monitoring reports dashboard on View your education data. This dashboard contains a set of reports, which identify data quality and eligibility issues.

Providers should ensure they review the reports and correct data regularly.

Learning support

Learning support is claimed at a monthly rate of £150 on the ILR. Excess learning support is claimed on the earnings adjustment statement.

For all funding streams, the funding rules clearly specify that learning support is available to meet the costs of putting in place a reasonable adjustment. It is for all learners with a learning difficulty or disability that affects their ability to continue and achieve their learning goal. This is set out in section 20 of the Equality Act 2010,

We provide learning support for apprentices with learning difficulties or disabilities as defined in Section 15ZA(6) of the Education Act 1996 (as amended by section 41 of the Apprenticeships, Skills, Children and Learning Act 2009).

This includes individuals who:

• self-declare a learning difficulty or disability
• do not have a diagnosis of a learning difficulty or disability, but the main provider has identified a learning need to us

We check that the:

• the claims for learning support are for learners with disabilities and difficulties
• there is evidence of an assessment to determine the support required and evidence of delivery of that support
• the support is reviewed to ensure it is still fit for purpose or continues to be needed
• the support is delivered, each month the support is claimed

Providers need to make sure that:

• learning support is not claimed for learners who did not have a disability or learning difficulty
• the reasons for learning support are not to fill a skills gap
• the assessment and support plans and reasonable adjustment has been considered

If there is no evidence to support the learner’s eligibility, all learning support funds for the learner are at risk.

Most overclaims where found when there was insufficient evidence that there was a reasonable adjustment delivered or in place for each monthly payment. If the learner is eligible, but there is a lack of evidence to support delivery each month where learning support is claimed, we class this as a funding error for the months where evidence is missing.

Other issues not leading to funding overclaims include:

• plan and delivery records being unclear, including the reasonable adjustment not being clear
• review of support not clear
• incorrect ILR from and to dates

Use the relevant funding rules for learning support, including, for apprenticeships.

Provider data self-assessment tool (PDSATs)

We review reports generated by the PDSAT to identify potential data anomalies in the ILR that may lead to issues and errors within the funding claim or earnings. This review will involve performing some testing of the data back to source documentation.

The DfE provides PDSAT to produce exception and listing reports for data review and cleansing. The user guide that accompanies PDSAT gives clear and comprehensive instructions on how to produce PDSAT reports and generate samples. You can access it at ILR data: provider data self-assessment toolkit (PDSAT). 

The following reports relate to those with significant overclaims in funds, due to the reasons listed.

A-504 Learners in learning beyond their learning planned end date:

• inaccurate completion status or learning actual end dates

Y-210 Withdrawals and planned hours for learners continuing from a previous year:

• no attendance
• hours not reduced - there were a significant volume of these
• hours contain ineligible learning activities
• incorrect hours leading to a funding underclaim

A-507 Learners resuming regulated learning aims:

• funding adjustments were not applied or applied inaccurately - there were a significant volume of these

B-007 Learners progressing to apprenticeships from 16 to 19 study programmes:

• hours not reduced following progression to an apprenticeship with the same provider

Y-301 Learners under 16:

• evidence packs did not contain sufficient evidence to demonstrate eligibility

Y-209 Completions, withdrawals or transfers within first 6 weeks:

• learners withdrawn or complete in the first 6 weeks, but the hours were not reduced to planned available
• incorrect actual end date, leading to underclaims in the planned hours

Y-201 Full-time learners on short study programmes:

• hours not reduced for late start
• incorrectly returned planned hours
• continuing learner from the previous year where hours were not reduced for the current year

A-103 All learners and learning aims within the apprenticeship programme:

• incorrect total negotiated price, including constituent delivery and assessment costs, as well as actual costs for own employees
• omitted LDM 356 to indicate delivery to own employees
• prior learning before Digital Apprenticeship Service reservation
• minimum duration not met
• planned end dates incorrect
• incorrect total planned off-the-job

Y-101 All 16 to 19 funding model learners and learning aims:

• band 1 incorrect hours
• summer starts
• early completer where hours were not reduced
• Ineligible due to age and status
• general incorrect hours, including split between planned learning and planned employability enrichment and pastoral hours, underclaims and overclaims

Y-205 Funded hours thresholds:

• general lack of attendance
• some hours not realistic, such as ineligible activity on bank holidays and breaks
• planned versus actual not realistic
• incorrect planned hours returned in the ILR

A-511 Early completions:

• no evidence of learning, or recognition of prior learning identified late
• no delivery of learning but straight to assessment
• incorrect completion status or learning actual end date

A-206 Apprentices undertaking level 1 or below in English and/or maths within an apprenticeship:

• initial assessment demonstrates higher level is attainable
• prior learning identified within evidence pack and Learning Record Service

Y-207 Withdrawals and qualifying days for funding:

• no attendance or incorrect start date

A-209 Negotiated prices as a proportion of funding band maxima:

• total negotiated price, including constituent figures for delivery and assessment costs, recorded inaccurately - including not matching agreed breakdown of price
• recognition of prior learning not accurately accounted for

Y-107 Summer term starts:

• all confirmed as summer starts and, due to in-year funding already received, they were not eligible

A-205 Employment status exceptions:

• alternative English apprenticeship did not apply
• incorrect actual end date
• evidence of redundancy not on file but obtained retrospectively
• self-employed status returned erroneously

A-503 Learning aims with actual duration of one day:

• no learning evidence of learning, or evidence of learning did not support the ILR dates

A-505 Withdrawals and qualifying days for funding:

• evidence did not support learning start or actual end dates
• no learning evidence

A-510 Long breaks in learning with no resumption:

• actual end date incorrect; and, in some instances, should be withdrawn, not on a break in learning
• lack of evidence to show learner intent to return, and in some instances, should be withdrawn, not on a break in learning

A-512 Completions without a full achievement:

• incorrect completion status, and in instances, the aim should be withdrawn
• prior attainment identified
• incorrect outcome status
• incorrect actual end date

Subcontracting

We check that subcontracting provision complies with the funding rules. We do not check for compliance with the subcontracting standard.

To avoid errors, providers need to make sure that:

• the ILR and subcontractor declarations are accurate
• subcontracts are in place and are signed before delivery starts
• funding delivered under subcontracts does not exceed the limits set out in the contracts
• contracts contain all the minimum clauses required by the funding rules, including adequate document retention clauses - for new starts these should be in the provider agreement and non-levy contract

Within the findings identified, the following areas relate to those with funding errors or resulted in significant non-compliance and recommendations. Although overclaims may not have been identified, the risk is that funding impacts might develop.

Issues to be aware of are:

• for apprenticeship provision, 100% subcontracting led to all funds being recovered from start
• for apprenticeship provision, insufficient substance to training or assessment led to funding errors ranging from partial to full funding from start
• details and subcontractors listed on the subcontractor declaration do not match the details recorded on the ILR
• provision not declared on the subcontractor declaration, the ILR, or both - there were a significant volume of these issues, including where a subcontractor declaration had not been submitted. It is a requirement for all providers to submit declarations, even if a nil return
• unclear documents regarding subcontracting relationships, including written agreements with the employer or subcontractor being non-compliant - the relevant funding rules provide specific guidance on content of agreements and should be used as a checklist for compliance purposes

Funding rules guidance

More information on the funding rules is available from:

• 16 to 19 funding: information for 2023 to 2024
• advanced learner loans funding rules 2023 to 2024
• advice: funding regulations for post-16 provision
• adult education budget (AEB) funding rules 2023 to 2024 - collecting, returning and checking the quality of ILR and other learner data.