EFA funding guidance for young people 2014 to 15

• Funding regulations 2014/15 – v1; and

• Sub-contracting controls regulations

- (Funding regulations – section 3: student eligibility

is explained in a separate presentation)

EFA Young People’s Funding Team

Funding guidance for young people: 2014/15The format of the funding guidance is the same as last year. It

consists of four separate books:

• ‘Funding regulations’ (published June 2014)

• ‘Funding rates and formula’ (published July 2014)

• ‘ILR funding returns’ (published August 2014) – this does not

apply to schools or academies

• ‘Sub-contracting control regulations’ (published April 2014)

All these documents are available at:

www.gov.uk/16-to-19-education-funding-guidance

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Funding: the aims

The 2014/15 funding methodology has several aims.

Continuing to simplify the funding arrangements, to let post-

16 institutions concentrate on delivering study programmes

that will meet young people’s needs as they progress to

employment or higher education.

Funding students so that study programmes can deliver a

broader focus and so that more young people who are

currently NEET can be recruited into further education and

training.

To meet the raising the participation age (RPA) requirements

for young people over the years ahead.

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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,

• not record funding for students who are enrolled on study

programmes funded by EFA at other institutions,

• avoid any multiple funding for the same provision within a

student’s study programme.

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Principles of funding learning (slide 2)

- Section 2 – paragraph 13

Institutions should (the last bullet point is new from 2014/15):

• 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, and

• ensure when entering the planned hours on data returns that

the hours entered are realistic and deliverable to each

individual student and that this can be evidenced if necessary

to any funding auditors.

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Principles of funding learning (slide 3)

- Section 2 – paragraph 14

Consulting EFA (this is unchanged from last year)

• Institutions are now only expected to discuss with the EFA any

circumstances that affect groups of students rather than

individual students.

• 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.

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Study Programme Eligibility

Section 4 and 6

• Study programme eligibility is set out in section 4.

• Evidence of student existence and eligibility is set out in

section 6.

• Section 6: table 1 now includes the words:• the planned hours recorded on data returns need to be supported by

auditable evidence of eligible timetabled activity.

• Student eligibility guidance (SEG) is set out in section 3 – see

separate companion slide presentation on SEG.

• Most students are now funded as full time students in the

allocations and this percentage is expected to increase in

future years to meet RPA requirements.

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Annex D – Condition of funding

All institutions should note that the condition of funding in

respect of English and maths set out in ‘Funding regulations’

2013/14 annex D is now repeated as annex D 2014/15.

But as stated in 2014/15 document paragraph 15:

The EFA will enter into grant agreements with individual institutions paid directly by

the EFA and with each LA for their maintained school provision. The grant

agreement will set out the funds that the EFA has agreed to pay for the education

and training provision expected to be delivered in return for that funding. These

include EFA conditions in respect of charges that may be made to students for their

provision. Annex D sets out the new condition of funding that applies to all

provision in respect of the delivery of English and mathematics within study

programmes from this year.

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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)

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Student enrolment requirement change from next year

Section 6 – paragraph 127 (g) – change for next year

from the 2015 to 2016 funding year confirmation that part-time

student are not enrolled on any funded study programmes at

other institutions must be included within these documents.

Institutions enrolling students on short part-time study

programmes are expected to use the Learner Record Service

and the student Personal Learning Record to verify that such

students are only attending their own institution.

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Questions and answers on study programme eligibility

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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

The EFA does 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 student’s study programme later in the year but as this will not

increase the student’s 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.

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Calculating, evidencing (and auditing) funding hours (Question 1a)

Q1a What about students who transfer between learning aims within

the start qualifying period?

A1a If the student transfers from a qualification before the qualifying

start period, then the timetabled hours up to the point of transfer may be

included in this field if they would make a significant material difference to

the learner’s total planned hours such that they would move from one

funding band to another.

If the learner withdraws from all their learning aims and leaves the provider,

the hours recorded in this field should not be amended.

(This answer is new in ‘Funding regulations’ annex C but is no different to

the final ILR guidance for 2013/14)

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Calculating, evidencing (and auditing) funding hours (continuation from previous slides)

Q1b (continued) Are there any permitted exceptions to the previous

answers?

A1b (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.

This advice 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, or to prevent institutions enrolling students who

may need to first participate in a shorter programme.

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Calculating, evidencing (and auditing) funding hours (Question 2)

Q2 How do I calculate the student’s 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 funded study programme hours after the

completion of the funding start period – six weeks attendance on the

student’s core aim.

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Calculating, evidencing (and auditing) funding hours (Question 3)

Q3 How do I evidence a student’s study programme hours?

A3 The EFA expects 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 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.

The EFA has set out for 2014/15 in paragraph 73 that planned hours must

be realistic and deliverable – see next slide.

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Calculating, evidencing (and auditing) funding hours (Question 3)(continuation from previous slide)

Q3 How do I evidence a student’s study programme hours?

A3 Paragraph 73 now states:

When entering the planned hours on data returns institutions must ensure

that the hours entered are realistic and deliverable to each individual

student. These need to be supported by auditable evidence of eligible

timetabled activity. The EFA has commissioned some additional audit work

in summer 2014 to ensure that the planned hours recorded are genuine

and this will be reflected in the audit programmes in due course for

2014/15.

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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 set out some simple general requirements that

must be met by each institution’s individual student administration systems.

The core requirements to evidence IAG, attendance and achievement are

still set out in section 6 of the ‘Funding regulations’ guidance. This advice

was simplified last year to assist institutions in meeting the core evidential

requirements of all the main education regularity bodies. The evidential

advice on enrolment form and learning agreement advice continues to

recognise and support those institutions that currently merge registers for

some individual learning aims.

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Calculating, evidencing (and auditing) funding hours (Question 4)

Q4 How do I evidence attendance by students on 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.

The planned study programme hours should not be affected by any

individual student’s non-attendance at individual learning sessions.

Institutions need to be able to show any funding auditors that the planned

study programme hours are deliverable to individual students

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Calculating, evidencing (and auditing) funding hours (continuation from previous slide)

Q4a (continued) What can be claimed for study/revision leave?

A4a (continued) As set out in paragraph 80 of Regulations 2014/15 :

Where students are allowed time away from the institution’s premises to revise and

prepare for exams this must also meet the criteria of being planned, being explicit in

the student’s timetable, and supervised and/or organised by a member of staff.

Study leave should be time limited and the weekly number of hours should not

exceed the student’s planned weekly hours for the overall study programme. Study

leave should be supervised or organised by the institution, for example by requiring

the completion of structured revision or practice papers that are marked by a

member of staff and where the student is given feedback. These hours can be

counted for both years 12 and year 13. The time when the student is taking the

exam can also be included in the total planned hours.

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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.

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Calculating, evidencing (and auditing) funding hours (Question 6)

Q6 What counts as work experience?

A6 The EFA has issued some generic advice on work experience within

study programmes:

16-19 study programmes: work experience

www.gov.uk/government/publications/post-16-work-experience-as-a-part-of-16-to-19-study-programmes

Delivery and recording of work experience

www.gov.uk/government/publications/delivery-and-recording-of-work-experience

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Students who started programmes in 2013/14 carrying into 2014/15 (Question 7)

Q7 How are carry over students funded in 2014/15? How do we treat

students who start in June/July on 600 hour programme and therefore

cross two funding years?

A7 No differently to new students in 2014/15. The study hours entered on

the ILR are specific to the funding year and therefore any student starting

their study programme in June/July 2015 will only have a very small

number of study programmes hours in the first year.

Students aged under 16 on 31 August 2014 and who start any study

programmes on or after 1 June 2015 will not be eligible for any EFA

funding. The minimum qualifying period for funding remains 2 weeks.

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19+ student funding in 2014/15 (Question 8)

Q8 Are 19+ students funded in 2014/15 by the EFA?

A8 No change to existing policy. Students aged 19 or over on 31

August 2014 are the funding responsibility of the SFA, other than

the following:

19-24 with either an LDA or EHCP,

students completing their study programmes in sixth form

colleges and schools who started their learning aims in

2013/14 whilst aged under 19 on 31 August 2013.

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19+ students funding in 2014/15 (Question 8) (continuation from previous slide)

Q8 Are 19+ students funded in 2014/15 by the EFA?

A8 No change to existing 2013/14 policy.

The EFA is making no concession to fund the students shown

on Row D of the FIS Funding claim report at FE colleges, LAs,

HEIs or CCPs for either 2013/14 or 2014/15. 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. If they hold

an SFA contract the students need re-coding to attract SFA

funding.

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Core aim determination and retention in 2014/15 (Question 9)

Q9 Can a short learning aim be recorded as a core aim?

A9 The advice on determining core aims (paragraphs 26-31) and

retention (paragraphs 36-39) is set out in companion document

‘Funding rates and formula’.

Determining core aims

In paragraph 26 the guidance states that the core aim is the most

important element of the programme, which will usually be the

component with the largest amount of timetabled activity

associated with it. For this reason the answer to the above

question will usually be no.

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Core aim determination and retention in 2014/15 (Question 9) (continuation from previous slide)

A9 (continued). Paragraph 38 in 2014/15 Rates and formula book

addresses this issue where groups of students have been recorded

doing short core learning aims:

The EFA will monitor the position with regard to short core aims

and retention, and will consider adjusting the retention rate for

individual institutions if there is evidence that cohorts of students

are entered for programmes that distort the retention rate in this

way. The EFA would only apply such an adjustment to institutions

whose data returns showed material non-compliance with the spirit

and intention of the funding methodology.

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Funding for students where they are following non-progression programmes and/or re-taking subjects or examinations

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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 6) and paragraph

61 on next slide

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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.

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Students on re-takes and re-sits (slide 1)

Explanation of EFA policy for paragraphs 107-109:

• The purpose of these paragraphs on re-sits and re-takes is

to avoid poor use of public funding, which would arise if large

numbers/groups of students who have not achieved their

desired grades are routinely funded for a further year. The

institution has already received funding to deliver the

qualifications for these students and generally, if students

wants to retake the course or resit the exam to improve

grades, our expectation is that they would be in-filled into

existing groups and no further funding would be claimed.

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Students on re-takes and re-sits (slide 2)

Paragraph 107 below (see also paragraph 14 – slide number 6):

• Where learning programmes are designed to enable students

to re-sit or re-take examinations and assessments, these are

not generally eligible for funding as the activity has already

been funded.

• 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.

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Students on re-takes and re-sits (slide3)

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. No study hours should be included in funding

returns for students merely re-taking examinations.

• 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.

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EFA Funding guidance for young peopleSub-contracting control regulations

Document published – April 2014

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Sub-contracting controlsRevised document from April 2014

• It should only be used by institutions either with sub-

contractors or those considering entering into sub-contracted

partnerships.

• The document has been updated from last year. The

document sets out for sub-contracted (includes any franchise

or partnership provision) some additional compulsory

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.

35

Sub-contracting – Funding regulations references

Paragraph 113

• 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 such 16-19 whole

programme provision subcontracted by institutions.

36

Sub-contracting controls (slide 1)

Paragraph references are from the ‘Sub-contracting provision

control regulations’ document).

Paragraph 24 (was paragraph 6 in the 2013/14 document)

• In deciding whether to fund subcontracted provision delivered

outside the institution’s normal recruitment area, the 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).

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Sub-contracting controls (slide 2)(continuation from previous slide)

• that the provision complies with the principles of study programmes as set out

in ‘Funding regulations’,

• the extent to which the parent institution is involved in delivery (for example,

teaching part of the programme or just providing financial and quality

assurance),

• that the amount of funding retained by the directly funded institution is

proportionate to the costs they incur in the management and administration of

the contract,

• 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,

• the location of delivery and the nature of travel to learn/travel to work patterns,

• the extent of student contact with the parent institution.

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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

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For more information and questions

Contact us

All academies: academy.questions@education.gsi.gov.uk

Other institutions should contact their geographical team:

ypnorthern.efa@education.gsi.gov.uk

ypcentralsw.efa@education.gsi.gov.uk

ypsouthern.efa@education.gsi.gov.uk

Visit the website

The four funding books are available at:

www.gov.uk/16-to-19-education-funding-guidance

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