Successful ESFA Audits rely on training providers being confident about the accuracy of their funding claims, and being able to back up decisions with robust evidence. Aptem’s recently released eBook provides information on how to prepare for Audit and maximise the support you can get from your apprenticeship management system – Aptem.
Hosted by Tony Allen, an expert and consultant in apprenticeships and compliance, and Freya Ni Chleirigh, Aptem Product Owner, this webinar complements the eBook and provides insights into:
- How to prepare for an ESFA Audit and what the auditors will be looking for.
- How you can use Aptem to help you prepare.
Q and A transcript
The following is a transcript of the questions asked during the webinar, along with the answers provided by product experts. For any further information, do contact your Implementation Consultant, Customer Success Manager or Aptem Support.
Thank you to everyone that attended for your questions during the webinar. Thanks too to Tony Allen and Freya Ni Chleirigh for providing these responses.
Where you have different funding rules for OTJ if a learner started June 2022 where OTJ was based on Work hours they move employers what OTJ method do we use do we use prior to Aug 2022 or Aug 2022 onwards?
Providing that the learner transfers to the new employer, and does not leave and restart, then it is the rules that were in place at the start of their apprenticeship, not those when they transferred.
If the learner is doing a short course, will they still be required to complete a minimum of 4 Progress reviews?
Not sure what you mean by a 'short-course'. All apprenticeships must be a minimum duration of 12 months. Even for a 12 month apprenticeship there must be at least 4 progress reviews.
Last Day In learning, if there is a 5-month gap and then a date of learning is recorded, am I correct to think that is not sufficient as a LDIL?
You cannot have a 5 month gap, with no learning and still claim funding. The learner must be put on a break in learning during this period, from the date of the last evidenced activity. If they then recommence learning, then funding can be claimed again. The LDIL must always be the last date of any evidenced activity.
With the OTJ on the weekends, we have apprentices who do work weekends in care sectors, would that be discounted?
OJT can only be evidenced during 'normal working hours', this excludes overtime. If a learner is contracted to work weekends, then OJT can be counted during a weekend, if they are not, then it can't.
Do the notes in the Skills Scan section keep a record of who added them (Learner/Tutor/Employer etc.)?
They don't at the moment, so it's a good idea to ask the learner, employer and tutor to add their initials to the comment.
In Aptem, can the RPL Calculator via the Tracker be created when a learner is in onboarding as opposed to delivery?
It can only be applied when the learner is on the delivery programme because the tracker takes the details from the delivery dates which are applied when you put the learner on delivery.
Do auditors speak to learners?
Will the audit be remote or face to face?
Now audits are back as face to face.
We use sub-programmes for mandatory quals within the apprenticeships, can the RPL calculator in Aptem account for the hours against these sub-programmes?
At the moment, the RPL calculator only accounts for the delivery programme the learner is on - we will take this feedback on board.
What's the difference between 'must' and 'should'?
If it is 'Must' then you have to do it in all circumstances. If it is 'Should' then you are expected to do it, unless there are specific reasons as to why you cannot.
On the requirement to state the profit element separately; is this a change? We've been advised by auditors in the past that the profit should not be listed separately, but rather should be built into the acceptable cost categories. The point they were making was that if we were to set out any amount that was outside of the acceptable cost categories, such as profit, then they would automatically claw that back.
The funding rules are not specific on this. However, in my experience it is good practice to set out the profit element separately. If you effectively hide it within the costs, then what you are showing are not your true costs, but also include the profit element. There is nothing wrong with being open about the profit component. The funding rules recognise this.
When you process a BiL tracker, if you don't put anything in the message to learner/tutor boxes, do they receive a blank notification or not? We've been putting things in the boxes even when it's not really required, in case it sent blank messages.
The learner/tutor will receive a standard notification to let them know that the tracker has been processed. If you populate the box, it will send them your message instead of a standard notification. This means that you won't have a scenario where the system sends a blank message, even if you don't populate the box.
Is everyone giving auditors access to Aptem? I know that's the advised method, but it still makes me nervous after being used to compiling a carefully curated set of documents with no access to our systems.... However, given that you can't download all the training plans for a learner in one click (for example) the intention is obviously that we should give auditors access.
You have a contractual obligation to give the auditor access to your learners' records, wherever they are kept.
Is there a recommended role we should give auditors when we give them access to Aptem?
Please see the support article here for details: Aptem system access when planning for an external inspection.
If you don't have a signature on a review but it has been recorded, would that be sufficient to show the review actually happened? We always try and get signatures but sometimes they just don't do it.
Whilst Ofsted would be happy, I am not yet certain that an ESFA auditor would be. They still operate under the need for signatures. You should still use a template (you can cut and paste from a transcription), and get that signed by the learner and line manager.
Would the 4 progress reviews include the eligibility and suitability review at the beginning and possibly the EPA gateway review or are they separate, so possibly more than 4 reviews would be needed?
No, they do not. The induction / training plan meeting at the start, and the gateway meeting at the end of the practical period, are in addition to the 4 progress reviews.
If no learning for a calendar month and the learner is put on a BIL, do you still plan for learning/visit for the forthcoming month or do you need to complete a separate visit/session to bring the learners back before you can continue with their journey?
If you believe that the learner will only miss a month, then you should plan accordingly for activity the following month. The key here is that you know what the learner is doing, and do not let their non-engagement drift.
If the off the job hours drop below the ESFA minimum allowed of about 280 per year, will you get an error message?
The OTJ hours dashboard indicates where the learner falls below the minimum required for their duration and working hours. The system calculates this based on information entered in the system (start and end dates, working hours per week). Aptem therefore identifies when learners fall below the minimum required, including for learners on a programme of the minimum duration.
Please could you advise on when funding and OTJ is reduced due to RPL i.e. 3 modules and the apprentice falls below the total minimum OTJ requirement as they have less planned OTJ than others in the cohort? They do however have the same start and end date as others in the cohort.
You decide this as part of the initial assessment process. If the learner has RPL, will removing that content take them below the 12 months minimum criteria? If so, then they cannot undertake the apprenticeship. If however, with their RPL hours removed they still will be in learning for more than 12 months, then they can undertake the apprenticeship. You should adjust start and finish dates accordingly, otherwise their OJT will be wrong. They cannot claim OJT for content that you have said is covered by RPL.
What are the forecast hours in the learning plan in Aptem?
The forecast is a sum of completed hours in completed components and planned hours in incomplete components in the learning plan.
Where in the funding rule is it stated that OTJ hours need to be removed if the price reduction has been made due to RPL and the apprentice is still required to attend?
See Para 78. You need to evidence OJT that supports the delivery of training set out in the Training Plan. If you have removed content due to RPL, then that must not be in the training plan. If it is not in the training plan, then you cannot count OJT activity against it.
Where is the requirement in the rules to map the OTJ hours to the KSBs. This is not in the template provided by ESFA?
See paras 67 & 68.3 OJT must be directly relevant to the apprenticeship standard. This is enshrined in the KSBs.
The rules suggest that the regular reviews can be changed if it's appropriate for planned learning. Does this mean there can be fewer than 4, for example 3 in a year if this matches module delivery plans?
There can be less than 4 per year if it fits with module delivery. However, this must be agreed with the employer (and therefore written down and evidenced). In addition, where the delivery suggests that 4 per year could have been undertaken, then that should be the minimum. There is also a massive Ofsted reason why there should be at least 4 per year. That is about judging learner progress.
What is the best method to do a check that the learner has no student loan or they don't use the loan to fund the app? Is it just self-declaration or there is a system to check it?
Self-declaration is sufficient.