The Department for Education have released their common findings from assurance work on post-16 education providers for 2023/24. While it makes for some very interesting reading, it doesn’t contain many surprises for the Solvendis team as the findings align with what has been identified in our own audit work. In 2023/24 we carried out 44 client audits and many of the issues identified in 2023/24 continue to be issues in 2024/25.
Off the Job Training (OTJT) is the biggest cause of funding errors identified in apprenticeship audits. Issues identified included:
- OTJT minimum requirements being incorrectly calculated meaning apprentices are not working towards or achieving the minimum required hours;
- The planned OTJT hours agreed not matching between the training plan, apprenticeship agreement and the ILR;
- Insufficient detail in the training plan to demonstrate the training activities planned and how they contribute to the agreed number of OTJT hours;
- Ineligible hours being recorded in OTJT records, resulting in the total eligible hours completed being below minimum requirements;
- OTJT records not being in place, or being insufficient to give assurance that the minimum OTJT requirements are being met;
- OTJT hours being completed outside of normal working hours; and
- No evidence of active learning each calendar month.
Other key areas of non-compliance identified are:
- Apprenticeship agreements and training plans either not being in place, not meeting all the criteria stated in the funding rules, not being fully completed, updated or fully signed, or signature processes not being suitably robust;
- Negotiated price not being broken down into eligible costs and agreed with the employer, including ineligible costs, or not matching the price agreed in the ILR;
- TNP2 not matching the price agreed with the End Point Assessment organisation, or being recorded as an estimate;
- Learning start dates not being supported with evidence of learning, or being recorded as induction when no learning has occurred;
- Learning end dates not being correctly recorded or not supported with suitable evidence to correspond with the last learning activity;
- Lack of evidence of an appropriate assessment of prior knowledge, skills and behaviours to identify any prior learning and experience, or prior learning or experience being identified, but no reduction in price or content (with no justification as to the reason);
- Not using an appropriate funding reduction for functional skills aims where learners resume learning;
- Lack of evidence to confirm eligibility criteria collected prior to the start of learning, such as residency status, and confirming the learner has the ability to complete the apprenticeship within the planned duration (including having a contract of employment to cover the full duration of the apprenticeship); and
- Functional Skills funding being claimed where exemptions are held.
Whether you are a College, University, Employer or Independent Training Provider, if you are not collecting the correct evidence to substantiate your funding claims, the money you have claimed could be at risk. Understanding where your gaps and vulnerabilities lie will help you to improve your processes and ensure that you are protected against possible clawback in audit.
Solvendis funding compliance audits have helped many providers identify the required areas of improvement. Our knowledgeable and supportive team will evaluate your risks and provide guidance on compliance. If you would be interested in booking a funding compliance scrutiny audit for your company, please get in touch.
