EFA Funding guidance for young people 2013 to 14

1. 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

2. 2 Funding guidance for young people: 2013/14 Format 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)

3. Funding in 2013/14 – the new methodology - purpose 3 • 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.

4. Principles of funding learning (slide 1) - Section 2 – paragraph 13 4 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.

5. Principles of funding learning (slide 2) - Section 2 – paragraph 14 5 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.

6. Study Programme Eligibility 6 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.

7. Compliance evidence – section 6 7 Records 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)

8. 8 Questions and Answers on Study Programmes eligibility

9. Calculating, evidencing (and auditing) funding hours (Question 1). 9 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.

10. Calculating, evidencing (and auditing) funding hours(continuation from previous slide) 10 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.

11. Calculating, evidencing (and auditing) funding hours (Question 2). 11 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

12. Calculating, evidencing (and auditing) funding hours (Question 3). 12 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.

13. Calculating, evidencing (and auditing) funding hours (continuation from previous slide) 13 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.

14. Calculating, evidencing (and auditing) funding hours (Question 4). 14 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.

15. Calculating, evidencing (and auditing) funding hours (continuation from previous slide) 15 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.

16. Calculating, evidencing (and auditing) funding hours (Question 5). 16 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.

17. Calculating, evidencing (and auditing) funding hours (Question 6). 17 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”.

18. Students who started programmes in 2012/13 (or before) (Question 7) 18 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.

19. Students who started programmes in 2012/13 (continuation from previous slide) 19 Q7 (additional) How do we treat students who start in June/July on 600 hour programme and therefore cross two funding years? A7The 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.

20. 19+ students funding in 2013/14 (Question 8). 20 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.

21. 19+ students funding in 2013/14(Question 8).(continuation from previous slide) 21 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.

22. 22 Funding for students where they are following non-progression programmes and/or re-taking subjects or examinations

23. Students on non-progression (slide 1) programmes 23 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

24. Students on non-progression (slide 2) programmes (continuation from previous slide) 24 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.

25. Students on re-takes and re-sits (slide 1) 25 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.

26. Students on re-takes and re-sits (slide 2) 26 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.

27. 27 EFA Funding guidance for young peopleSub-contracting controlsDocument published - August 2013

28. Sub-contracting controls 28 Separate 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.

29. Sub-contracting – Funding regulations references 29 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.

30. Sub-contracting controls (slide 1) 30 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).

31. Sub-contracting controls (slide 2)(continuation from previous slide) 31 • 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.

32. Sub-contracting controls - the main paragraph references shown below 32 • 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

33. 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