In para. 151 of the new funding rules 2018/19, where it says “Learners..and cannot contribute towards the cost of co-funding fees”, would anyone know how would we evidence this or would a self-declaration from the learner be sufficient?
Many thanksJune 1, 2018 at 4:06 pm #261573
it’s literally the next paragraph! 😉
152. You must see and keep supporting evidence in the learner file. This could be a wage slip within 3 months of the learner’s learning start date, or a current employment contract which states gross monthly / annual wages. Please note this is not an exhaustive list, but must support your decision to award full funding to an individual who would normally be eligible for co-funding.June 1, 2018 at 4:09 pm #261576
I saw this, however I thought this only applied to the £15k, but I guess if they are just happy with the wage siips/ employment contract as evidence, then a self-declaration from the learner to declare they cannot afford the co-funded learning as well is sufficient?
Many thanksJune 1, 2018 at 4:19 pm #261580
We were debating this earlier – isn’t it a retro. step to start taking copies of folk’s financial details?! Surely it would have been enough for providers to sign to say they have seen the evidence and what it was, etc? Even that’s a bit much, as pretty much everything else is self-dec. these days
An absolute headache for data protection too! Has anyone at the Agency considered ‘data minimisation’ in this
…and now we’ll all have to update our new privacy notices just days after publication!
KateJune 1, 2018 at 4:27 pm #261582
That’s a really good point, even if you’ve evidenced the wage, that doesn’t mean they can’t pay. You could have an individual on a very low salary because their partner or parent earns a huge amount, and are financially supporting them. It could be someone who is semi-retired after a very lucrative career.
I suspect we may have a statement that says something about them feeling unable to contribute. If nothing else, it might just deter some people from trying to claim full funding when they could easily afford it. That feels somewhat humiliating though, asking someone to sign something that essentially says “I cannot afford this”.
I don’t think an auditor could ever catch us on that one, as long as we’d evidenced the salary, but I just morally don’t like that a very wealthy person can get a freebie on a technicality.June 1, 2018 at 4:33 pm #261584
Also, we don’t have to offer this. The rules say we “may”. We could just keep this up our sleeve for students who express concern about the fees. Many don’t bat an eyelid, and just pay up.June 1, 2018 at 4:37 pm #261586
Kate, that was exactly my thought about privacy statements! I might hang fire and see if we get V1.1 of the Rules in a month or so…
Ruth, with self-dec EVERYONE can get a freebie if they want (and I will defend self-dec to the death), you have to think about how likely fraud/taking advantage of the system is (not very) and how much it helps everyone else (loads).June 1, 2018 at 4:38 pm #261588
Re: the “may”, i think it rather depends if you want that sweet sweet extra 3% of AEB we’ve been promised if we over-deliver next year…June 1, 2018 at 4:40 pm #261590
Haha! Yes, that’s not my decision to make fortunately 🙂
Agreed, I fully support self-declarations, and I don’t think we have much fraud, if any. This rule doesn’t even need a self-declaration though, it just needs wage evidence. I think what Jazz was suggesting is, do we also have a self-declaration about the “cannot contribute” bit. I’d prefer to say “If you feel unable to pay this fee, and your annual wage is less than £15k, you can be fully funded” than just “If your annual wage is less than £15k, you can be fully funded”.June 1, 2018 at 4:54 pm #261592
Do you all think that para 151.2 means that if the reason that the learner earns less than £15,736.50 is that they work less than 37.5 hours per week this makes them ineligible?June 1, 2018 at 8:39 pm #261626
Per 152 in the funding rules make’s it clear you only have to see the evidence, it does not say you have to keep a copy of it, but that you must evidence in the learner file what evidence you have seen to support eligibility for full funding.
A self-declaration from the learner would not suffice as evidence as the Provider must have seen the evidence and recorded this in the learner file.
I do wonder why Providers complicate what is a simple requirement.
June 2, 2018 at 10:00 am #261721
- This reply was modified 4 months, 2 weeks ago by Martin West.
Liam, you’re not the first to mention this. I’m 98% sure that it’s just an explanation of how they got to the £15k figure and that part timers will definitely be eligible, I’ve got a call into the service desk for conformation (as have at least two others! hopefully we’ll all get the same answer).
Martin “and keep” reads more like photocopies of wage slips than a note to say we’ve seen them? it doesn’t say “and keep” on stuff about learners who haven’t been here three years?June 3, 2018 at 5:39 pm #261973
I read it as ‘you must keep the evidence in the learner file that you have seen the supporting evidence which could be either be a wage slip within 3 months of the learner’s learning start date, or a current employment contract which states gross monthly / annual wages’, but I accept it is open to interpretation.
What it does not say is that a learner declaration alone will suffice.June 4, 2018 at 9:35 am #262107
Martin, it’s not in question whether a self-declaration will be enough, it says very clearly that we need evidence. The question is, should we also collect a self-declaration to evidence “who are employed and cannot contribute towards the cost of co-funding fees”. I guess it’s not our problem if the government choose to create a loophole that allows wealthy people to claim full funding, but the rules do specifically say “cannot contribute”. Will an auditor pay attention to that bit?
Declaration or not, we certainly wouldn’t simply advertise that you can get full funding if your salary is below £15k, we would always use wording like “cannot contribute”.June 4, 2018 at 11:30 am #262148
I think you are misinterpreting 151 as you are only required to meet the requirements of 151.1 and 151.2, there is no requirement to confirm that they ‘cannot contribute towards the cost of co-funding fees’.
It’s a bit like ‘the boy stood on the table with 3 legs’
HTHJune 4, 2018 at 11:43 am #262153
I don’t believe I’m misinterpreting it, just perhaps being overzealous. The very clear purpose for this full funding is to enable people to study, who cannot otherwise afford to pay. We just don’t seem to have to evidence that bit.June 4, 2018 at 11:53 am #262158
It definitely sounds like paragraph 152 is saying that copies should be taken.
You must see and keep supporting evidence in the learner file.
Because of the way the sentence is written, whatever is the object of ‘see’ must also be the object of ‘keep’.
You must [see and keep] [supporting evidence] in the learner file.
On the question of self-declaration, there’s no indication that we need to ‘prove’ that the student cannot pay the co-funded rate. We just need to be satisfied the learner meets paragraphs 151.1 and 151.2.
I agree that this could leave the door open for individuals with high household incomes to claim full funding, and that probably is not the intention of the additional funding pathway.
Like Ruth says, I don’t think it’s an option that we’re required to provide (or even advertise) – it’s just something that we can make available depending on learner circumstances.June 4, 2018 at 12:42 pm #262170
The reference in Par 151 text to ‘who are employed and cannot contribute towards the cost of co-funding fees’ is misleading as a learner would not be unemployed where working a 37.5 hours and earning £15,000 p.a.
I only raise these issues in the hope that the ESFA will understand the importance of the wording used in the funding rules to avoid any confusion.
HTHJune 4, 2018 at 1:40 pm #262189
Apologies if this comes through more than once…….
Being as we are not required to collect this type of personal data for any other reason , please could the Agency advise how long they would like us to keep students income details for (bearing in mind this is a year long pilot and we still need to comply with data protection legislation)?
– until R14 / possible Funding Audit
– for Financial Memorandum
– until 2030 for ESF Match (although no-one can tell us who gets matched, so we will have to
keep them all…..just in case!)
Thanks very muchJune 4, 2018 at 3:50 pm #262223
I do not think there is any requirement to collect student’s income details excepting where you may use Par 151 to fully fund those in receipt of low wages in which case you will have to retain evidence that you have seen evidence that they earn less than low pay threshold.
HTHJune 4, 2018 at 4:41 pm #262233
Yes thanks Martin …I understand that this is something new and different.
Most of our students, with these circumstances, would have gone to our Discretionary Support Fund (part of the AEB) to help cover their tuition and we do not have to keep copies of benefit/wages slip etc for this purpose, just record the detail – Hurray!
Now if we give them full funding instead, we have to keep copies of what I would suggests is highly personal data.
My point really is would we just keep this evidence for possible funding audit and then destroy. Otherwise it will be kept for a further 12 years….we have to tell students how long we are going to keep each bit of data for.June 4, 2018 at 4:58 pm #262235
We get staff to sign to say they have seen appropriate evidence of things (and what it was), but don’t keep copies of the actual evidence. We do it with Qualifications and Identification. I’m hoping that something similar with salary evidence will be acceptable to auditors.June 4, 2018 at 5:04 pm #262239
I think I’ve missed something here!! Are these Apprenticeship funding rules?
Can someone send a link I have the Apprenticeship funding policy from August 2018 but not any funding rules and can’t find any on gov.uk
BeverleyJune 6, 2018 at 9:00 am #262655June 6, 2018 at 9:09 am #262662
Thanks Martin, thought it was Apprenticeships. must have been wishful thinkingJune 6, 2018 at 9:12 am #262667
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