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EFA Funding guidance for young people 2013 to 14
Funding regulations 2013/14 – v1.01; and
Sub-contracting controls guidance
- (Funding regulations – Section 3 – Student
Eligibility is explained in a separate presentation
- EFA Young People' Funding Team
Funding guidance for young people: 2013/14Format similar to previous years:
• Funding Regulations (version 1 published May 2013 version
1a published June 2013)
• Funding Rates and Formula
• ILR Funding Returns (does not apply to schools or
academies)
• Sub-contracted controls guidance (previously published in
Section 7 in Funding regulations 2012/13)
2
Funding in 2013/14 – the new methodology - purpose
• To meet the objective to simplify the funding arrangements
and enable post 16 institutions to concentrate on delivering
study programmes that will meet young peoples needs as they
progress to employment or higher education.
• To fund students rather than individual learning aims and
remove the previous funding restrictions of “guided learning
hours” so that study programmes can deliver a broader focus
and that more young people who are currently NEET can be
recruited into further education and training.
• To meet the Raising Participation Age (RPA) requirements for
young people over the years ahead.
3
Principles of funding learning (slide 1)
- Section 2 – paragraph 13
Institutions should:
• only record funding for students assessed as eligible for EFA
funding under Section 3 of this document,
• avoid recording funding for students who are enrolled on study
programmes funded by EFA at other institutions,
• avoid recording EFA funding for any part of any student’s
study programme that duplicates that received from any other
source, for example other EFA funding, funding from either the
Skills Funding Agency, Higher Education Funding Council for
England (HEFCE) or from any other source.
4
Principles of funding learning (slide 2)
- Section 2 – paragraph 14
Consulting EFA (this is a significant change from 2013/14)
• Institutions are now only expected to discuss with the EFA any
circumstances that affect groups of students rather than
individual students throughout the funding guidance
documents. For circumstances that only affect an individual
student the institution is expected to make any necessary
decisions itself within the spirit of this guidance and simply
record their decisions as audit evidence in accordance with
usual student enrolment processes.
5
Study Programme Eligibility
Section 4 and 6
• Study Programmes eligibility is set out in Section 4.
• Evidence of student existence and eligibility is set out in
Section 6.
• Student eligibility guidance (SEG) is set out in Section 3 – see
separate companion slide presentation on SEG
• Most students (84%) are funded as full time students in the
2013/14 allocations and this percentage is now expected to
increase in future years to meet RPA requirements.
6
Compliance evidence – section 6Records of student existence and eligibility (Funding
regulations - paragraph reference numbers in brackets):
• Recording study programme hours including timetabling (121 -
124)
• learning agreements and enrolment forms (125 – 128)
• student attendance (129)
• register (not necessarily subject specific) (130 - 133)
• withdrawal/transfer forms (134)
• Achievement (135 – 137)
• Documentation – originals held by institutions not sub-
contractors (138)
7
Questions and Answers on Study Programmes eligibility
8
Calculating, evidencing (and auditing) funding hours (Question 1).Q1 Should the planned funding hours be altered after the student has
attended past the initial start qualifying period (usually six weeks into their
programme)?
A1 NO - as most students will be funded as full time students the
answer is simple. The EFA do not expect institutions to make changes to
the student programme hours during the year but to simply calculate the
planned study hours within the initial part of the student’s learning
programme and then enter them on the ILR. Institutions may agree to add
additional learning aims to the students study programme later in the year
but as this will not increase the students funding there is no requirement to
increase the overall study hours. Similarly, if students cease to attend
some of their non-core learning aims during the year there is no
requirement to reduce the study hours.
9
Calculating, evidencing (and auditing) funding hours (continuation from previous slide)
Q1 (continued) Are there any permitted exceptions to the previous answer?
A1 (continued) Yes. Students who are only recruited to start short study
programmes and who at the completion of their short study programme are
then recruited by the institution on to longer study programmes. The advice
on the next slide applies equally whether or not there is any gap between a
student initial short study programme and their longer study programme.
The intention to simplify the funding arrangements is not intended to act as
a barrier to any institution encouraging all their students to attend a full
time study programme and that some students may need to first participate
in a shorter programme.
10
Calculating, evidencing (and auditing) funding hours (Question 2).
Q2 How do I calculate the students ILR study programme hours?
A2 The EFA expect this to be calculated after the student’s initial advice
and guidance (IAG) is completed and for some students this may need to
include their initial attendance on part of their overall study programme but
no changes are expected to the ILR funded study programme hours after
the completion of the funding start period – six weeks attendance on the
students core aim
11
Calculating, evidencing (and auditing) funding hours (Question 3).
Q3 How do I evidence a student’s ILR study programme hours?
A3 The EFA expect this to be through the IAG documentation process. The
planned study hours as part of the IAG process should be explained to the
student and documented so as to show a timetable of expected student
attendance that cumulates to the ILR study hours. This is no different to
the existing educational practices found in most institutions as students
need to know where to go in order to attend their required study
programmes.
12
Calculating, evidencing (and auditing) funding hours (continuation from previous slide)
A3 (continued) The EFA is not setting out any definitive guidance to
institutions on standard forms etc as it is not our intention to prescribe
exactly how each autonomous institution calculates and evidences their
study programmes but to simply set out some simply general requirements
that must be met by each institutions individual student administration
systems. The core requirements to evidence IAG, attendance and
achievement as set out in Section 6 of Funding Regulations remain for
2013/14. This advice has been simplified for 2013/14 to assist institutions
in meeting the core evidential requirements of all the main education
regularity bodies. This simplification is to fully merge previous enrolment
form and learning agreement advice and to recognise and support those
institutions that currently merge registers for some individual learning aims.
13
Calculating, evidencing (and auditing) funding hours (Question 4).
Q4 How do I evidence attendance by students on ILR study programme
hours?
A4 Institutions are expected to have register systems in place that are
sufficient to track student attendance. The major benefit of such systems to
the institution should be to enable institutions to tackle any non-
attendance issues as early as possible before they reach the point where
the student withdraws from their study programme.
14
Calculating, evidencing (and auditing) funding hours (continuation from previous slide)
Q4 (continued) How do I evidence attendance by students on ILR study
programme hours?
A4 (continued) The planned study programme hours should not be affected
by any individual students non-attendance at individual learning sessions.
To try and assist institutions in the transition year of the introduction of this
new funding methodology the EFA see the planned study hours as broadly
equivalent of an overall listed rather than unlisted programme in terms of
the previous funding methodology. Institutions should however, as
previously for unlisted learning aims, be able to show any funding auditors
that the planned study programme hours are deliverable to individual
students.
15
Calculating, evidencing (and auditing) funding hours (Question 5).Q5 Does the EFA have any advice on what activities can be counted as
study hours? (see also Funding Update 2013/14 – paragraph 28)
A5 Planned hours are those that are timetabled, organised and/or
supervised by the institution, and take place in line with the institution’s
normal working pattern to deliver the Study Programme, and can include
the following:
Planned tutor led activity on qualification bearing courses for the
student in the academic year;
Planned hours of tutorials, work experience or supported internship
for the student in the academic year, and planned hours on other
activities that are organised and provided by the institution, such as
sport or volunteering for the student in the academic year.
16
Calculating, evidencing (and auditing) funding hours (Question 6).
Q6 What counts as work experience?
A6 The EFA has issued some generic advice in Funding Update 2013/14
paragraphs 43 – 52 for advice on “Other Hours”.
17
Students who started programmes in 2012/13 (or before) (Question 7)
Q7 How are carry over students funded in 2013/14?
A7 No differently to new students in 2013/14.
Only one funding system exists in 2013/14 and all institutions should map
their existing students from the old system to the new system. The vast
majority of EFA funded students are full time students and so institutions
will be expected to both deliver and record funding above the full time
funding threshold for their carry in full time students.
For part time students institutions should simply record the study
programme being delivered during 2013/14. The previous funding
methodology split programmes on an exact day count between funding
years so the overall impact on the funding is expected to be small.
18
Students who started programmes in 2012/13 (continuation from previous slide)
Q7 (additional) How do we treat students who start in June/July on 600
hour programme and therefore cross two funding years?
A7 The study hours entered on the ILR are specific to the funding year and
therefore any student starting their study programme in June/July will only
have a very small number of study programmes hours in the first year.
Institutions are reminded that students can only be claimed for funding
once each year and most young people will already have been funded for
the year.
The minimum qualifying period for funding is 2 weeks.
For 2013/14 the LIS funding calculation programme will exclude for funding
all students who are aged under 16 on 31 August 2013 and who start any
study programmes on or after 1 June 2014.
19
19+ students funding in 2013/14 (Question 8).
Q8 Are 19+ students funded in 2013/14 by the EFA?
A8 No change to existing policy. Students aged 19 or over on 31
August 2013 are the funding responsibility of the SFA, other than
the following:
19-24 LLDD
Students completing their study programmes in sixth form
colleges who started their learning aims in 2012/13 whilst
aged under 19 on 31 August 2012.
20
19+ students funding in 2013/14 (Question 8). (continuation from previous slide)
Q8 Are 19+ students funded in 2013/14 by the EFA?
A8 No change to existing 2012/13 policy.
The EFA is making no concession to fund the students in
group 2 above at FE Colleges, LA, HEI or IPP for either
2012/13 or 2013/14. Any of these institutions without SFA
contracts should consider carefully when recruiting students
whose study programmes run into a following year after the
student has attained the age of 19 on 31 August whether they
should refer the student to another institution that has both an
EFA and SFA contract.
21
Funding for students where they are following non-progression programmes and/or re-taking subjects or examinations
22
Students on non-progression (slide 1)
programmes
Paragraph 19:
• Institutions must be able to demonstrate educational
progression for students recruited onto programmes funded by
the EFA and be able to record evidence of good educational
reasons for any individual students recruited to programmes
which do not provide progression.
• See also paragraph 14 (as set out on slide 5) and paragraph
61 on next slide
23
Students on non-progression (slide 2) programmes (continuation from previous slide)
Paragraph 61:
• The programme eligibility guidance reflects the Government’s
view that it is not for the Government or its agencies to
determine either which individual qualifications a student
should take, or to develop or generate new qualifications.
Institutions through their information, advice and guidance
(IAG) processes should determine the curriculum offer to meet
the needs of students including their HE entry and
employment entry needs.
24
Students on re-takes and re-sits (slide 1)
Paragraph 107 below (see also paragraph 14 – slide number 5):
• Many learning programmes are designed to enable students to
re-sit or re-take examinations and assessments and these are
not generally eligible for funding as the activity has already
been funded. In 2013/14, as a transitional measure, the EFA
will fund individual students who re-take qualifications.
• Subsequently re-takes will not generally be eligible for funding,
but where there are exceptional circumstances outside the
control of the student or institution, such as a period of long
term sickness, or good educational reasons then the re-take
delivery hours for individual students may be included in the
funded study programme hours.
25
Students on re-takes and re-sits (slide 2)
Paragraphs 108-109 below
• Where a student fails to complete a learning aim in the
expected time span and stays on for additional time, including
revision sessions or re-sits, no further funding should be
recorded.
• Qualifications leading to a GCSE grade A*-C in English and/or
maths where the student has not yet achieved a grade C in
these subjects are not treated as retakes for funding
purposes.
26
EFA Funding guidance for young peopleSub-contracting controls
Document published - August 2013
27
Sub-contracting controlsSeparate document from 2013/14
• It should only be used by institutions either with sub-
contractors or those considering entering into sub contracted
partnerships.
• The document is broadly similar to Funding regulations
2012/13 Section 7. The document sets out for sub-contracted
(includes any franchise or partnership provision) some
additional compliance advice to remind funded institutions that
the previous eligibility advice on controls over such provision
remains both a matter of good practice and relevant in
avoidance of funding fraud.
28
Sub-contracting – Funding regulations references
Paragraph 113 (the second part is new from 2013/14)
• Historic funding eligibility problems have more often arisen
where students are attending institutions outside of their
normal recruitment area, particularly where this involves sub-
contracted provision and in such cases additional safeguards
are required from institutions for all such delivery.
• Given the known risks of irregularity in distance sub-
contracting, the EFA will not normally fund 16-19 provision
subcontracted by institutions outside their normal recruitment
areas. ‘Normal recruitment area’ means the area from which
most 16-19 students travel to learn at the institution and this is
explained in paragraphs 52 to 54.
29
Sub-contracting controls (slide 1)
Paragraph references are from the Sub-contracting provision
controls guidance document).
Paragraph 6 (new requirement from 2013/14)
• In deciding whether to fund subcontracted provision delivered
at a distance from an institution’s main site(s) on an
exceptional basis, EFA will take into account a range of factors
including, but not limited to:
• (the factors are listed on next slide and the font size here and on the
next slides has been slightly reduced so they all fit on one slide).
30
Sub-contracting controls (slide 2)(continuation from previous slide)
• whether the provision complies with the principles of study
programmes as set out in Funding Regulations;
• whether the whole or part of the programme is subcontracted and the
extent to which the parent institution is involved in delivery (eg
teaching part of the programme or just providing financial and quality
assurance);
• the location of delivery and the nature of travel to learn/travel to work
patterns;
• the extent of student contact with the parent institution;
• the extent to which the provision being made is already available and
accessible to students in the area where the subcontract is delivering;
• the extent to which a gap in provision has been identified by the LA or
an employer.
31
Sub-contracting controls - the main paragraph references shown below
• 12- 14 Contract advice - control test advice set out in 14
• 15- 20 Procurement – 15 to 20 - Traineeship requirements in 19
• 21- 27 Due diligence
• 28- 32 Controls over students, tutors and provision
• 33- 34 Controls over qualifications and curriculum
• 35- 36 Other EFA funded students
• 37- 41 Monitoring (control) visits and spot checks
• 42- 43 Sub-contractors with multiple institution contracts
• 45- 46 Advice to Accounting (Principals/Head Teachers)
• Note: some key control check advice set out in 38 and 39 and 46
32
EFA Funding guidance for young people 2013 to 14
Funding regulations 2013/14 – v1.01; and
Sub-contracting controls guidance
- (Funding regulations – Section 3 – Student
Eligibility is explained in a separate presentation
- EFA Young People' Funding Team
