Do you have up to date information on your actual income?

It has always been important to have up to date information on the income being generated by learners across all funding streams. Best practice management accounts and reports to the board should show this income earnt and not just the allocation. To do this, providers need to have accurate learner data readily to hand at all times. This can be a challenge, especially for multi-sited dispersed provision. The Education and Skills Funding Agency (ESFA) has recently issued ‘ILR Data Integrity Guidance’. This is in response to changes in the Audit Code of Practice for 2020/21 but provides useful advice for all providers on sources of assurance over their data.

At RSM, we have continued to work with many providers to assess and provide guidance on how they can gain assurance over new requirements and have engaged in regular dialogue with the ESFA on evidence requirements and potential funding implications of non-compliance with the various funding rules.

In this briefing note we complement the ESFA guidance and look at some of the data areas that may need review and challenge as well as the key themes and lesson learnt from recent funding assurance reviews. This note addresses 16-19 study programmes, Adult Education Budget and advance learner loans. We have produced a separate note on apprenticeships which can be accessed Apprenticeship here.

Adult Education Budget

English and maths

The main area where there is often insufficient evidence to support funding claims relates to English and maths. In particular:

  • providers being unable to demonstrate that an appropriate diagnostic, of the level the learner is performing at, has been carried out;
  • learners not being enrolled on a level above that to which they have been assessed as performing. Common reasons for this are that the learner has a ‘spiky profile’ and, therefore, has been enrolled on the level at which they have been assessed to ensure that they can progress. There would be a concern if the learner had then gone on to complete the learning aim in an unrealistically short period of time; and
  • we have seen an increase in providers enrolling learners on non-regulated maths/and or English at the same time as the bona fide qualification which follows the same curriculum. This has meant that the non-regulated learning aims are not eligible for funding.

Additional learning support

Additional Learning Support is claimed monthly at a rate of £150 a month. Evidence of learning support delivery should be maintained for each month that the additional support is claimed. Our reviews identified cases where sufficient evidence could not be provided for the months that support had been claimed, resulting in an overclaim.

Duplication of learning

We have noted an increase in the number of learners who are either repeating learning aims they have already achieved or are studying the same course at the same time with another provider. This has led to learning being duplicated. There is a risk of funding overclaim at the institution with the later enrolment.


When learners are transferred from a 90-credit diploma to the extended diploma there is a requirement to make a funding adjustment to the extended diploma based upon the prior learning from the 90-credit diploma. We have noted that in most instances this is not being amended on the ILR, leading to a funding error.


Increasingly providers are erring on the side of caution when it comes to applying the full or co-funding indicators and applying the latter. When the learner then provides evidence of their full-funding eligibility later down the line the ILR is not being amended which is leading to a funding underclaim.

16-18 Study Programme learners

Distance learning during Covid

Providers have re-timetabled a number of times during Covid to account for virtual lessons, which in many cases has led to a reduction in the overall planned hours. This has not always been amended on the ILR. In addition, providers have not always kept registers for remote learning which has made evidencing learning attendance and, therefore, the learner’s ability to achieve the 42 day qualifying period for funding more difficult.

Withdrawals in first 42 days of the study programme

It is a requirement of the ESFA funding rules that, where a learner withdraws from a learning aim within the first 42 days of the study programme that the remaining planned hours or the withdrawn aim are either removed from the ILR or re-tasked into the study programme. Where learners have been completely withdrawn for the academic year, and are enrolled onto programmes of less than 24 weeks planned duration, we have noted the lack of amendment to planned hours on the ILR and therefore the provider has overclaimed.

Classification of hours

We continue to find planned hours that are misclassified. Planned hours for non-regulated aims or work experience (unless specified by the awarding body) must be recorded as Employability, Enrichment and Pastoral (EEP) activity rather than planned learning hours. Whilst there are no funding implications for this type of error it does produce data errors which need to be corrected.

Condition of funding

Meeting the Condition of Funding in relation to learners holding or obtaining a relevant English and maths qualification at Level 2 (GCSE 9-4) continues to be a point of discussion, with key issues being:

  • learners not meeting Condition of Funding as they withdraw from the English and/or maths aim prior to 42 days. In some cases, the learners have not attended at all but are recorded as active;
  • learners not enrolled on an eligible aim; and
  • learners who have GCSE English Literature grade C but are not flagged as having met the Condition of Funding for English.

Industrial placements

A continued issue is the use of the industrial placement work experience code in the ILR. Where the learner is undertaking an industrial placement, evidence needs to be available to show that they have achieved the 315 minimum hours requirement. In addition, these hours should not be included within the planned hours on the ILR.

19-year-old continuing students

Our reviews have identified instances where students who were funded through the study programme methodology in one year and continued into the next academic year, did not have any additional, new aims funded through that route and instead they were claimed through the adult model. If a learner is continuing from one year into the next all aims should be funded through the study programme route.

Apprenticeship (FM36) learners on study programme aims

We are increasingly seeing some overlap with learners who are studying or transferring from 16 to 19 study programmes to apprenticeships. Learners who are undertaking apprenticeships should not be funded through 16 to 19 study programmes for their English and Maths aims, this instead should form part of their apprenticeship aims on the ILR.

Where learners are transferring from a 16 to 19 study programme to an apprenticeship in the same funding year, the learners 16 to 19 planned hours should be reduced to reflect the hours actually delivered to avoid a funding overclaim.

Advanced Learning Loans

There is often inconsistency between the provider’s underlying records and the information on the loan portal, particularly in relation to:

  • inconsistent planned start and end dates. This is important, as the monthly funds paid to the training provider are based on the planned period of learning;
  • inconsistent learning aims. The amount of loan awarded is linked to the course type, fees and the maximum loan available for the course. Incorrect recording of learning aims on the portal could, therefore, mean that incorrect loan values will be awarded;
  • inconsistent personal details. Submission of incorrect personal details to the Student Loans Company could result in learners not being able to be traced to ensure that repayments are made when applicable; and
  • loans flag being recorded on the ILR when no loans funding had been drawn down, either because the learner loan application had been rejected, or because the learner had withdrawn before any funds had been drawn down.

It should be noted that the provider cannot change most of these details as it is the responsibility of the learner to advise the Student Loans Company of the original information and any changes in circumstances. It is therefore important that a reconciliation exercise is carried out between the ILR and the portal to ensure that any errors are identified, and a new Learning and Funding Information Letter should be provided if necessary. Where providers are not accurately recording learning end dates on the portal there is the risk of additional funding being drawn down and thereby adding to the debt that the learner will have to repay.