Familiar Findings, Clearer Signals in DfE’s Common Findings Report

The publication of Common findings from funding assurance work on post-16 education providers: 2024 to 2025 assurance year provides a useful snapshot of the compliance issues identified through DfE funding assurance work. Several themes will be familiar, including planned learning hours, learner eligibility, withdrawals, ILR accuracy and supporting evidence. However, a comparison with the previous year’s report reveals notable differences in the findings and the level of detail.

Those differences are worth recognising because they indicate where DfE has detected funds at risk and where DfE wish providers to take note of and address those risks. Auditors, just like the rest of us, are driven by experience. Where they have found patterns of errors before their eye will be drawn to the potential for these in future audits. A savvy provider will use the report to ensure their compliance; both with management controls to prevent the error and with audit work of their own or externally engaged to identify non-compliance and correct it. Forewarned is forearmed.

16 to 19 Provision: Greater Clarity on Overclaims and Non-Compliance

One of the clearest differences since last year’s report appears within the latest report’s 16 to 19 provision section. This section distinguishes between findings associated with significant overclaims especially in substantiating planned hours, and those resulting in substantial volumes of non-compliance and recommendations without the need to put funds at risk once alternative evidence has been obtained, such as evidence of being in learning for at least the qualifying period. This distinction helps providers understand the difference between issues that directly resulted in funding recovery and those where weaknesses in controls, evidence or processes were identified but had not yet resulted in funding loss. Reading between the lines is important here. Providers don’t want to have to argue their case and fall back on alternative evidence in the hope that it will get them over the line. The goal must be to have the required evidence complete and accurate, naturally recording this during planning and delivering programmes. The report also notes that some findings for condition of funding English and maths carried a risk that future funding could be affected despite no overclaim for the year audited.

Within 16 to 19 provision, learner eligibility and confirmation of the learning agreement now appear as standalone findings. Although elements of these risks were reflected elsewhere in the previous year’s report, their separate treatment now gives them clearer emphasis.

The eligibility section identifies instances where learners were deemed ineligible and highlights weaknesses relating to residency evidence, eligibility controls and supporting documentation. Eligibility is paramount to every funded learner. Without evidence of eligibility all a learner’s funds would be at risk, which can very quickly result in high error rates. This can potentially take providers over the 5% error rate threshold, where the audit opinion is unsatisfactory and DfE will audit the provider again in the following funding year.

The confirmation of learning agreement section focuses on issues such as agreements being incomplete, unsigned, missing altogether or signed significantly after the learner started.

Neither area represents a new funding requirement. However, their standalone treatment provides a clearer indication of the documentary and eligibility weaknesses identified through audits.

Apprenticeships: Greater Visibility of Key Compliance Risks

The apprenticeship section contains several standalone headings that either did not appear in the previous report or have been separated from broader findings. These include:

• Completion of the practical period or programme. Unsurprisingly from typical findings of my team’s work, minimum off-the-job training not being met is a common error.
• 16- to 18-year-old apprentice; which focusses on incentive payments to employers. In this year’s funding rules, providers now have a framework to follow to avoid sitting on incentives not paid to employers. If the employer does not respond to three attempts in three months, the payment should be returned.
• Gateway assessment. The most common error being incorrect recording of completion, where the learner was actually withdrawn or still in learning. There was also a significant volume of apprentices where confirmation of employed status was not clear at gateway.
• Payment of employer co-investment. The funding rules have changed for 2026 to 2027 removing the link between co-investment and the completion payment. Do be aware though that DfE are still auditing 2025 to 2026 funding and will be until early 2027.

Knowledge, Skills and Behaviours is now divided into assessment and outcome. No assessment, or an unclear assessment, creates funding risk through uncertainty over whether minimum off-the-job training hours and duration requirements would still apply after accounting for prior learning. Another risk is being unable to confirm the accuracy of the negotiated price without understanding the impact prior learning has had. Not agreeing the outcome with the employer, even where no prior learning adjustment is required, is a common finding. So too is failing to adjust the training plan where prior learning has been identified. Underclaims also arise where unnecessary adjustments are made because the funding rules methodology has not been applied correctly. Funding is hard earned. The last thing anyone wants from an audit is to be told they failed to claim funding they were entitled to.

Providers reviewing their controls may wish to focus on the above, as well as reported high volume risk areas including eligibility around evidencing checking residency and right to work, and off-the job training (OTJT). Once again OTJT is cited as the most common cause of errors. Whilst the risk of miscalculation of planned OTJT is resolved by adhering to the minimum hours now being published on the Skills England website, not evidencing delivery remains a risk. Common errors include missing monthly evidence, inclusion of ineligible activities, bulk uploads of hours with no breakdown of dates and times to confirm they occurred within working hours, hours prior to start or during a break in learning not being eligible. Again, all regularly seen on my team’s mock funding audits. When these are removed from the total hours delivered for completed apprentices, DfE put all funds at risk for apprentices that have not met the minimum hours. There is zero tolerance for such errors. I have seen that even a shortfall of one hour results in DfE recovering all the funding for that learner’s apprenticeship; as it is deemed ineligible. Again, multiple cases can very quickly lead to an error rate over 5% and the implications that arise from that.

Adult Skills Fund: Greater Focus on Data Accuracy and Achievement

Delivery location postcode and learning aim achievement receive standalone reporting.

The delivery location postcode findings include examples that resulted in significant overclaims as well as situations that could result in underclaims. The learning aim achievement section focuses on insufficient achievement evidence and inaccurate recording of completion and outcome data, with achievement or completion payments potentially at risk without the corroborating evidence.

These are not new themes, but their standalone treatment indicates they are a recurring theme at audit. These put them alongside longstanding common findings arising from eligibility, prior attainment, evidence of learning including to support the reported start and end dates, and evidence to support full funding claims.

Advanced Learner Loans: Clearer Expectations for Data and Documentation

One of the clearest examples of increased detail can be found within the Advanced Learner Loans section.

The previous year’s report dealt with several issues under a broad Learner Information heading covering consistency between the Learning and Funding Information Letter, learning agreement, Student Loans Company portal and ILR. By contrast, the 2024-25 report separates these matters into distinct sections covering:

• Change of circumstances and transfers
• Entitlement to full funding
• Learning actual end date
• ILR consistency with the loans portal and Learning and Funding Information Letter

The underlying risks are not all new, but the revised structure provides a clearer and more detailed explanation of the associated controls, reconciliations and evidence requirements. For providers with significant loans funded provision, the additional detail provides a more practical framework against which internal controls can be reviewed.

PDSAT: How DfE Uses Data to Identify Risk

PDSAT itself is not a new feature of the common findings report. However, the 2024-25 report provides much greater detail on individual PDSAT reports and the specific issues identified through them. This additional detail shows how DfE used specific PDSAT reports to identify potential anomalies and test underlying data against source documentation.

Utilising the Findings: Strengthening Your Compliance and Funding Assurance

The report should be viewed as more than a summary of assurance activity. It gives providers a practical benchmarking tool, highlighting the funding errors, compliance weaknesses and evidence issues identified through DfE assurance work. The additional detail included in the 2024-25 report is particularly valuable, offering greater visibility documentation requirements that sit behind many of the findings, and the controls required to achieve compliance.

Used effectively, the report can act as a checklist for internal reviews, data analysis and housekeeping, audit readiness exercises and periodic mock funding audits. An independent mock audit, informed by the common findings and undertaken by reviewers with a strong understanding of funding rules and assurance expectations, can provide valuable assurance that controls are operating effectively and highlight weaknesses before they result in funding errors, recommendations or recovery of funds. Arranging a mock funding audit should not be taken lightly. Those leading the review should be highly conversant with the common findings, the relevant funding requirements and the evidence needed to support funding claims, as well as the DfE audit team’s stance on errors and quantifying funds at risk. The objective should be not merely to identify error, but to recommend practical improvements that reduce the risk of errors recurring.

Ultimately, one of the most effective ways to improve compliance is to learn from the weaknesses already identified through assurance work elsewhere in the sector rather than waiting for the same issues to be discovered during your own audit.

By Rupert Crossland, Director of Audit and Compliance, Professional Assessment Limited