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: 2014/15 The 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-educationfunding-guidance 2 3 Funding: the aims The 2014/15 funding methodology has several aims. Continuing to simplify the funding arrangements, to let post16 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. 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. 4 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. 5 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. 6 Study Programme Eligibility 7 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. 8 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. Compliance evidence – section 6 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 subcontractors (138) 9 Student enrolment requirement change from next year 10 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. 11 Questions and answers on study programme eligibility 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 noncore learning aims during the year there is no requirement to reduce the study hours. 12 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) 13 Calculating, evidencing (and auditing) funding hours (continuation from previous slides) 14 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. 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. 15 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. 16 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. 17 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. 18 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 nonattendance 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 19 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. 20 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. 21 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-apart-of-16-to-19-study-programmes Delivery and recording of work experience www.gov.uk/government/publications/delivery-and-recording-of-workexperience 22 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. 23 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. 24 19+ students funding in 2014/15 (Question 8) Q8 Are (continuation from previous slide) 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. 25 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. 26 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. 27 28 Funding for students where they are following nonprogression programmes and/or re-taking subjects or examinations Students on non-progression programmes 29 (slide 1) 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 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. 30 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. 31 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. 32 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. 33 34 EFA Funding guidance for young people Sub-contracting control regulations Document published – April 2014 Sub-contracting controls Revised document from April 2014 • It should only be used by institutions either with subcontractors 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 subcontracted provision and in such cases additional safeguards are required from institutions for all such delivery. • Given the known risks of irregularity in distance subcontracting, 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). 37 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. 38 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 39 40 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