It may not be the sexiest topic, but getting your assurance processes right from the beginning will save you a lot of heartache in the long run, says Steve Hewitt, Lead MIS and Funding Consultant at FEA.
If you’re one of the large number of new providers entering the market as a prime contractor for the first time, either as part of the Levy Apprenticeship funding or the Adult Education Budget (AEB) funding procurement round, there are a lot of things to think about as you engage your first directly-funded learners.
Over the last couple of months, I’ve spoken to quite a few providers keen to make sure they’re doing everything right, which is heartening to hear. Some of them have previously been sub-contractors and some are moving into training for the first time, but they’re all facing similar issues, so here are four top tips to make sure you’re not going to trip up.
- Read the Funding Rules
Whilst this might sound like the most obvious thing to say, I was recently contacted by someone who asked “So, if our Apprentices are doing their induction in mid-September, I can put their start date as 1 September, right?” Hopefully I won’t need to spell out to most of you why this is wrong as you’ll be all too aware that start date is the first day of LEARNING and that induction is NOT LEARNING, in and of itself. This may be an extreme example, but you really really need someone in your organisation who has a good understanding of how the funding rules work or you will end up in serious trouble. An ESFA auditor will not accept ignorance of the rules as an excuse, they’ll just take the money back from you.
- Make sure your processes are fit for purpose
I’ve discovered that providers who are also sub-contractors are often required by their primes to collect far more evidence than I’d consider necessary or even sensible. It’s a long-term bugbear of mine, but no provider should be taking photocopies of UK passports to prove eligibility of learners. Apart from anything else, there’s a real issue of identity fraud if you’ve got a pile of photocopies in a filing cabinet! Provided you clearly ask the learner on your enrolment form if they have been resident in the UK or EU for the last three years (and what their status is if they haven’t), that’s all you need to record as evidence for funding. In terms of AEB funding, all claims for unemployed learners can be done via self-declaration, there is no requirement to photocopy or even see proof of benefit. According to colleagues at ESFA, this was actually a request by DWP/Job Centre Plus as they do not have the resource to produce evidence for all of their clients who want to do a course. If I could fix one thing about the current system, it would be to stop every provider in the country from asking for this “proof” from learners.
Having said all that, we still need an amount of paperwork (even if it’s electronic “paper”!) to make sure that we can effectively claim funding for the learners we’re working with. Again, the funding rules are your friend here, they concisely and clearly set out what you need to provide.
- Help your board to understand their role
If this is your first foray into direct delivery, you need to ensure that your board understands their obligations and need to scrutinise what you are delivering. Ofsted report after Ofsted report shows that this is an area of concern for inspectors. To do this, you need effective, timely management information that shows key metrics for your areas of work. This doesn’t need to be a whizzy, graphics-filled (expensive) dashboard, it just needs to be accurate and clear. If your board doesn’t have much experience in training, you will need to help them understand what is important and what questions they should be asking. From my point of view, governors need frequent assurance that the funding being claimed is being claimed correctly, long before an ESFA auditor walks through your door. Whether this assurance is carried out internally or externally will depend on the size of your team and the volume of provision you offer, but it’s something you neglect at your peril.
- Don’t be afraid to ask questions
The various streams of funding, the vagaries of data collection and complexity of the work we are doing means that NO ONE KNOWS EVERYTHING. I’ve been doing this for fifteen years and still have to check with colleagues on some dark corners of the business. If you’re a new provider it’s ABSOLUTELY FINE to ask questions.
Obviously, if you want a truly definitive answer to your question, the ESFA Service Desk is the only place to get it. This implies, however, that you have a fortnight to wait for your answer. Luckily, there are other places where you’ll be able to connect with other providers who may well be in the same position as you.
If you are using a proprietary student record system, find out if your supplier has a user group or even an email list for users, sign up and join in. Although they may be focused on the specific software, I’ve never found one where you can’t also ask questions about best practice, funding and eligibility.
Training sessions organised by experts are also usually a good investment, not just for their opinions, but also because you’ll be in a room full of people facing the same issues you are. I usually end up getting as much from the chats over coffee and lunch as from some of the other sessions.
Finally, there is FEConnect which, although set up by ESFA, features little direct input from them these days. However, there is a lively community of practitioners who will happily answer questions and share your problems and frustrations.