We have had a number of apprenticeship providers request information pertaining to ESFA audit requirements on the evidence that is accepted for use where apprentices have ‘undiagnosed’ LDDs (learning difficulty or disability) or where apprentices do not have an LDD, but require additional support in order to meet the learning requirements of the apprenticeship. According to Mencap ‘Mental health problems can affect anyone at any time and may be overcome with treatment, which is not true of learning disability’.

Due to the ESFA Funding Rules, learning support is typically used to support apprentices with diagnosed learning difficulties or disabilities such as dyslexia, autism etc. and providers do not think the eligibility requirements for an undiagnosed LDD or mental health need allows them to support apprentices with the specific learning support needs to ensure effective learning and completion of the apprenticeship.

A number of providers have discussed that the lack of clarity from the ESFA, audit challenge and the processes underpinning learning support is off-putting to ensure learners are treated in a fair way to complete their learning. There is a clear lack of clarity in the eligibility criteria, coupled with the complexity of evidencing for audit is stopping providers delivering learning support to apprentices that require learning support.

With this in-mind, according to the Mental Health Foundation:

  • 20% of adolescents may experience a mental health problem in any given year.1
    • 50% of mental health problems are established by age 14 and 75% by age 24.2 
    • 10% of children and young people (aged 5-16 years) have a clinically diagnosable mental problem3, yet 70% of children and adolescents who experience mental health problems have not had appropriate interventions at a sufficiently early age.
    • One in four people in the UK will experience a mental health problem in any given year.

There is a lack of clarity in terms of evidence and identification to support apprentices with an undiagnosed LDD or mental health condition, the providers that we have spoken that do not utilise additional learning support for apprentices with an undiagnosed LDD or mental health condition is because they do not know what evidence would be acceptable to the ESFA, and if the ESFA Funding Rules will allow to support a learner that needs specific support.

We would like to see the ESFA be clearer in their rules, evidence, and audit requirements, specifically for learners who need additional learning support and have an undiagnosed LDD or mental health condition. This will support learners with needs that affect their learning and can ensure a fairer approach to learners requiring additional support.

A research report commissioned by the DfE and carried out by the Learning and Work Institute in 2018 (Exploring the funding and support for apprentices with additional support needs) highlights the issues that providers are finding, and where many providers have spoken with us. Within this report it suggests appropriate examples where the ESFA would clarify the funding rules to allow for additional learning support where apprentices have an ‘undiagnosed’ LDDs or where apprentices do not have an LDD, but require additional support in order to meet the learning requirements of the apprenticeship (anxiety etc). The report suggests:


  • What evidence and supporting information is required: Including what forms of evidence are acceptable if there is an auditing requirement and examples of the level of detail required. 
  • Who is eligible: Clearly establishing the types of support needs the funding is aimed at and any specific restrictions on eligibility. 
  • What can the funding be used for: Outlining what specific types of support or resources can different funding types be used for and what is not allowed.

We would like the ESFA to go further and open up additional learning support to allow for inclusivity of learning and apprenticeship completion, and define where learning support needs can cater for apprentices who do not have an LDD, but require additional support in order to meet the learning requirements of the apprenticeship, as per the Mental Health Foundation findings, which will have a direct result on learners learning and being successful.

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