Advanced Learning Loans Guide - A guide to 24+ Advanced Learning Loans for independent training providers
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Advanced Learning Loans Guide A guide to 24+ Advanced Learning Loans for independent training providers
Foreword The introduction of 24+ Advanced Learning Loans from August 2013 represents a significant reform for our sector, one that will have lasting implications for both providers and the employers and learners you work with. Preparing for the introduction of Loans will no doubt have impacted on all areas of your business, from your financial management and information systems, to the support, and the information, advice and guidance you provide for your learners. A Loans Readiness Survey carried out amongst AELP members in April this year indicated that providers are well on their way with preparations for the implementation of Loans. However, the Survey also highlighted a number of areas of concern, and it is these areas that this guide is designed to address. There is already a lot of information and support relating to Loans available from the Learning and Skills Improvement Service (LSIS), the Skills Funding Agency and the Student Loans Company. This guide aims to help you navigate these resources so that you can easily find the most useful to you and your organisation. We are very grateful to the Skills Funding Agency for providing the support to develop this guide. We hope that you find it helpful. Stewart Segal Chief Executive, AELP 2
Contents Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Policy overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Preparing for Loans readiness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Financial implications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Loans and your customer base . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Curriculum viability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Fee setting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 VAT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Managing on-programme funding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Management of the Loans Bursary Fund. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Data and information systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Data and evidence requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Data reporting and transfer between delivery partners . . . . . . . . . . . . . . . . . . . . . . . . 16 Managing learner and employer contributions to course fees . . . . . . . . . . . . . . . . . . . 17 Communicating the Loans message . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Briefing staff . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Marketing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Learner IAG, recruitment and enrolment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Ensuring quality and consistency across delivery partners . . . . . . . . . . . . . . . . . . . . . 22 Managing customer complaints related to Loans . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Appendix: At a glance: information links and contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 3
Introduction For the academic year 2013/14, government grant funding has been withdrawn for learners aged 24 and above who are studying for qualifications at Levels 3 and 4, and those taking Advanced or Higher Apprenticeships. To support affected learners, 24+ Advanced Learning Loans (Loans) have been introduced to help them pay up-front tuition fees for a course or programme at Level 3 or 4 that has been approved for public funding. As of April 2013, learners can apply for a Loan for a course or programme starting on, or after, 1 August 2013. In April 2013, AELP carried out an online Loans Readiness Survey amongst its members. The areas of concern identified in the Survey have influenced the formation of this guide. They are dealt with in three sections – financial implications, data and information, and communicating the Loans message. At the end of each section, you can rate your organisation’s Loans readiness. Policy overview The policy to introduce Loans was originally set out in the reform plan document New Challenges, New Chances published by the Department for Business, Innovation and Skills (BIS) in December 2011. Tighter resources have resulted in government grant funding being prioritised for those aged under 24 or those studying at Level 2 or below. The introduction of Loans funding maintains access to learning for those outside the priority groups by providing finance for learning. Loans are available for eligible learners aged 24 and above, taking eligible qualifications at Levels 3 and 4, including those on Advanced and Higher Apprenticeships1. The Loans operate on the same basis as higher education (HE) loans, with no repayment until the student has finished their course or programme and is earning above £21,000 annually. The Skills Funding Agency, Student Loans Company and HMRC are the key implementation partners of the Loans funding system. The Skills Funding Agency is responsible for: • identifying the providers eligible to deliver Loans-funded provision; • identifying the learning aims and Advanced and Higher Apprenticeship frameworks eligible to be funded through a Loan, and the associated maximum Loan amounts; • Loans Facility and Bursary Fund allocations to providers; • funding rules; • provider contracting; • payment of Loans Bursary Funding allocations; • performance and budget management. 1 Relevant qualifications have to be approved for funding and listed in the spreadsheets detailing the maximum Loan amounts for 2013/14 provided by the Skills Funding Agency. Qualifications include QAA Access to HE Diplomas, QCF Certificates and Diplomas, Advanced and Higher Apprenticeships, and AS/A-level programmes (exceptions exist for TUC learning aims and ex-military personnel). Funding and Loans for qualifications above Level 4 will only be available for Higher Apprenticeships at Levels 5 and 6. 4
The Student Loans Company is responsible for the administration of Loans by: • assessing Loan applications from learners; • making Loan funding payments to providers; • processing the changes to learner circumstances that affect their Loan; • managing Loan repayments from learners (together with HMRC, via the tax system). Preparing for Loans readiness The introduction of Loans is a significant reform for the further education (FE) sector. If you are an independent training provider (ITP) delivering Level 3 and 4 provision for the 24+ market, you will need to factor the availability of Loans into your business plans and consider the impact this will have on your organisation’s systems, processes and people. You will need a senior-level manager to lead your Loans implementation. There are strategic decisions to be made as you identify how the change in funding for 24+ adult learning at Level 3 and 4 will impact on: • the mission and strategic objectives of your organisation; • your priority areas for teaching and learning; • your market in each of your operational curriculum areas. There are implications for all your services – learner support and information, advice and guidance (IAG), financial services, management information systems (MIS), marketing and communications, and human resources. There may even be an impact on staffing levels (e.g. IAG or curriculum staff) and/or a need for staff redeployment. As the Loans application system for learners has already gone ‘live’, you should be completing your Loans readiness implementation to ensure that you are ready to advise, and make offers to, potential learners (and their employers) who want to undertake Loans-funded training programmes from August 2013. The Loans Readiness Survey revealed that most ITPs are well on their way with their Loans implementation plan. There are resources available to help you understand the Loans policy and its implementation: • Policy Overview and Frequently Asked Questions (SFA, April 2013) • Funding Rules 2013/14 (SFA, March 2013) • LSIS 24+ Advanced Learning Loans provider toolkits – four toolkits covering strategy and planning, finance and data, communication and collaboration, and quality and the learner experience • A guide to 24+ Advanced Learning Loans for colleges & other providers – an FE Week (newspaper) supplement. 5
Financial implications The Loans funding system works very differently to that of grant-funded provision. • From August 20132, adult learners (aged 24+ at the start of their learning) will need to fund their Level 3 and 4 learning requirements. They may do this by paying for it themselves, through employer contributions, via a Loan (if eligible), or a mixture of these. • The Skills Funding Agency has identified those providers that are eligible to deliver Loans funded activity in 2013/14 and has provided Loans Facility allocations to these providers3 based on their Loans-type activity4 in 2011/12 with a £5,000 de minimis to ensure that each provider has a realistic possibility of offering Loans-funded learning. • The Loans Facility shows you the expected maximum value of Loans-funded learning you would be able to deliver in 2013/14. The value of the Loans Facility is not guaranteed funding; actual funding will be paid based on the number of learners who take up a Loan with you as their provider. You may find that you are not able to fully utilise your Loans Facility. On the other hand, if the uptake of your Loans-funded provision looks set to exceed your Loans Facility, you may be able to extend it (see 24+ Advanced Learning Loans Budget Management for information on how to do this and for a Loans Facility Adjustment Request Form). • Learners can apply for a Loan ranging from a minimum of £300 up to the value of either the course fee or the funded rate set by the Skills Funding Agency (whichever is lowest). For Apprenticeship frameworks, the funding rate (and maximum Loan amount) assumes an employer contribution (50% minimum of the fully-funded rate). • Approved Loans will be paid by the Student Loans Company directly to the provider on the learner’s behalf. Payments will be made in equal monthly instalments starting two weeks after the start of the learner’s programme (the initial liability point) and continue as long as the learner is on programme (and as long as the programme duration is no longer than the maximum set for the type of learning aim5). • If a learner leaves the programme early without completing, the Student Loans Company will cease to make payments on behalf of that learner. If the learner leaves the programme having completed the qualification aim earlier than planned, the balance of the Loan amount for that learner will be paid in full at the next payment date. • There is no separate payment for achievement and job outcome payments do not apply. From June 2013, you will be able to track your learners’ approved Loans and your usage of your Loans Facility through the Learning Provider Portal. The change from grant funding to Loans funding has financial implications for your Level 3 and 4 provision. The Loans Readiness Survey identified several areas where ITPs have concerns and these are considered in the remainder of this section. 2 Loans funding only affects new 24+ learner starts from 1 August 2013. Those who start Level 3 or 4 courses before this date will remain eligible for grant funding until they complete their learning aim. 3 Approved providers are entered on the Register of Training Organisations and in receipt of an Adult Skills Budget (ASB). Note that not all ASB providers have a Loans Facility, but all were given the option to have one. 4 Loans-type activity was identified from a provider’s R15 Individualised Learner Record (ILR) and covers government-funded starts amongst learners aged 24+ on Level 3 or 4 provision (ASB): A-levels (including AS and A2), Apprenticeships, Higher Apprenticeships, Access to HE, and Level 3 and 4 Certificates or Diplomas. 5 The maximum payment durations are as follows: AS/A2 and A-level(s) – up to two years for each separate A-level; QAA Access to HE Diploma – up to two years; QCF Level 3 or 4 Certificate – up to two years; QCF Level 3 or 4 Diploma – up to three years; Advanced or Higher Apprenticeship – up to three years. 6
Loans and your customer base One of the greatest concerns amongst ITPs is that replacing grant funding with fee paying and/or Loans funding will result in increased course fees and/or debt-aversion. Both could dissuade significant numbers of potential learners (and/or their employers) from starting learning, particularly during the first year of implementation (2013/14). This would reflect the dip in HE enrolments seen in both 1998 and 2006 when up-front payment of fees and loans were introduced in that sector. However, BIS research suggests that attitudes to Loans and self-funding may be quite positive, with over 70% of affected Do … learners prepared to undertake learning without government Research the attitudes to self- funding. funding and Loans amongst your own customer base. Provider experience varies, and it is likely that the learner appetite for self-funding (including Loans) will differ across Create positive messages, the country as well as across socio-economic boundaries and briefings and literature so that employment sectors. your customers can see the value of investing in learning at Some areas causing ITPs particular concern include those Level 3 and 4. outlined below. • Reduced enrolments in employment sectors that are predominantly low-paid, such as the care sector. However, Look at … while learners in these sectors may be more likely to be debt- Research on learner attitudes to averse, they are also less likely to reach the Loan repayment Loans: threshold and so, in practice, may never have to make any repayments. • Attitudes to Further Education Loans (BIS, May • Higher and Advanced Apprenticeship frameworks that are 2012) made up of a package of learning aims proving to be too • 24+ Advanced Learning expensive for learners and their employers to fund and which Loans: Specific Learner may, at best, need to be replaced by training based solely Groups (BIS, January 2013) around the technical/vocational qualification. • What learner research tells • Employers cutting back on support for employee training due us – a short summary of to the increase in fees and withdrawal of grant funding. some of the research, including important lessons Early consultations with your learner and employer base can for Loans communications help you assess their motivation for undertaking learning at Level 3 and above, their attitude to Loans and the wider Gathering learner and employer concept of fee paying, and to identify any difficulties that voice and marketing: particular learner groups may have with accessing Loans. • LSIS Loans Toolkit 3: Make sure that, when you approach your learners and Communication and employers during this consultation process (and later with collaboration your marketing), your conversations are not corrupted by misconceptions or a negative focus on ‘loans’ and ‘debt’. Take the opportunity to find out what information they want from you and how they want to receive it. 7
Curriculum viability The viability of your current curriculum offer can be modelled using learner recruitment predictions based on statistics from previous years moderated by (preferably informed) estimates on: • the willingness (or otherwise) of your prospective 24+ learner cohort to fund their learning through paying for themselves, employer contributions or taking out a Loan; • anticipated demand from employers for training older (24+) employees now that government funding has been withdrawn. Understanding the attitude of your customer base to fee paying and Loans funding (mentioned in the previous section) means that you can make the introduction of Loans funding an important opportunity to work with learners and employers to review your provision and ensure that it meets their needs. Some employers may not have previously contributed to their employees’ training under the grant-funded system (even though they were supposed to). Other employers that do contribute may find that some fees (and their contributions) have increased. In either case, employers may now be tempted to cut back on employee training wherever they can. To offset this, talk to your employers to find out what they really want from the training you offer and how you can meet these needs through focused, cost-effective qualification aims and time Do … efficient delivery methods and programmes. Perhaps you can offer a single vocational or technical Certificate/Diploma instead Review your curriculum offer in of a multi-qualification framework, or change the length and partnership with your learners cost of a training programme by delivering a proportion of it via and employers to provide an optimum ‘fit' for the current e-learning. economic climate. Self-funded learners are likely to be more careful about the training they invest in. As with employers, make sure that your curriculum offer is both cost- and time-effective, and offers real Look at … work and/or life enhancements to learners. Reviewing your curriculum For provision that looks like it may become non-viable under viability: the new funding regime, check whether it could be adapted • LSIS Loans Toolkit 2: (e.g. to a different delivery format or qualification aim) before Finance and data deciding to drop it altogether. On the other hand, you may be able to identify provision opportunities that will allow you to work with new employers or learner groups. 8
Fee setting The Skills Funding Agency has provided two spreadsheets detailing the maximum Loan amounts for 2013/14 (one for learning aims and the other for Apprenticeship frameworks). These values are a significant factor in your fee-setting strategy as they set the maximum value of the Loan that a learner can take out for that learning aim (including any VAT). For the majority of ITPs, the maximum Loan rate is being seen as the maximum course fee that can be charged. The Learning Aim Rates Service (LARS) replaces the Learning Aim Reference Application (LARA) from 2013/14. Do … It should be live from August 2013. Discuss your proposed fee As funding information for qualifications approved for changes with delivery partners. 2013/14 is available in the Simplified Funding Rates Make sure your fees are catalogue, it will not be rolled over in the current LARA. transparent and available through course literature and your website (together with options for payment). You may charge a higher course fee than the maximum Loan amount, but you would have to secure other means of funding Be prepared to handle for the amount above the maximum rate – this would usually objections from learners or mean direct payment by the learner or the employer. employers about fee changes. Prepare some positive Charging less than the funding rate may beat the competition messages for inclusion in and attract more learners – but will you still be able to resource responses to enquiries about the provision adequately and maintain quality? Reducing the fees. fees may be an option where a learner has prior attainment contributing to the qualification aim they are applying for (so will Monitor the impact of your fee setting on enrolments. require less delivery input) or for a course that is the start of a strong progression route (using it as a ‘loss leader’). Fee setting primarily involves understanding what your Look at … customers value and are willing to pay for, how much they are prepared to pay, and whether you can meet those requirements Policy and funding rates: at that price. You may have to consider changes to staff • Maximum Loan Amounts and and resource utilisation, particularly if you change aspects Simplified Funding Rates of delivery (e.g. combining groups of learners from different catalogue qualification aims for the delivery of common elements or units, changing delivery location or time, or increasing the element • Funding Rules 2013/14 (SFA, of distance/online learning), or if you need to employ staff March 2013), pp 54-59 differently (e.g. on short-term contracts). • Policy Overview and Besides your own delivery costs, the fees you charge for a Frequently Asked Questions course should cover the cost of everything necessary for the (SFA, April 2013), section 5, pp 16-20 learner to participate in, and complete, the course, such as essential materials/tools and accreditation fees. Your fee-setting strategy: Don’t forget to find out what your competitors are doing to • LSIS Loans Toolkit 2: implement Loans funding, particularly in their curriculum offer Finance and data – see the and course fee charges. tool ‘Factors affecting fee setting’ 9
VAT For many ITPs, their requirement to charge 20% VAT is causing the greatest concern. They feel that this will put them at a considerable disadvantage compared with other providers who don’t have that requirement (such as colleges) as learners and employers may, at first glance, view the non-VAT-charging providers as a more cost-effective option. There are no easy answers here as there is no national policy support to mitigate the potential impact on ‘for-profit' providers of having to include VAT on course fees. Do … If you are an affected provider, you can only try to mitigate these risks through your own fee-setting and curriculum Look for ways to minimise strategies. Perhaps: the impact of VAT charges on recruitment. • lower your fees so that your fees + VAT are equivalent to competitors’ fee-only charges; there are clearly risks to both quality and viability in this approach, but it may be worth Look at … considering if local competition is strong and you feel that the risk of learner migration to other providers is high; Policy on VAT: • provide added value to your provision to justify your • Policy Overview and perceived higher course fees and to encourage potential Frequently Asked Questions customers away from your competitors. (SFA, April 2013), section 12 If you sub-contract from a VAT-exempt organisation, you may not need to charge VAT. This will depend on your contractual position and you should always check with HMRC. 10
Managing on-programme funding As mentioned earlier, approved Loans will be paid directly to the provider on the learner’s behalf in equal monthly instalments as long as the learner is on programme (you will confirm learner attendance to the Student Loans Company on a quarterly basis). Your budgeting systems will need to be adjusted to cope with this new type of ‘drip-feed’ funding, although you may already have similar systems in place if you currently offer payment by instalments to learners and/or employers for full-cost provision. Where there is sub-contracted provision, finance systems will also have to accommodate the regular transfer of on-programme funding between the lead and sub-contracting partners. One concern raised by some ITPs in the Loans Readiness Survey was the loss of funding when, for any reason, a learner leaves a programme early without completing. However, this issue is not Do … specific to Loans funding; it already applies to contract providers Talk to delivery partners about and, from 2013/14, all provider earnings will be dependent upon how on-programme funding learner retention. This makes an already important area worthy of will be paid, particularly where even greater attention from providers. To minimise risk, accurate Loans funding is involved. and comprehensive IAG is required when matching customers to courses, and high-quality delivery and programme resources are Review your IAG and quality needed to keep learners on programme. procedures and systems to maximise learner retention. It is worth noting that the experience from HE is that learners Ensure learners are on the right (and, by implication, their employers) are more committed to course and are satisfied with completion when they are paying for their learning. However, the programme delivery and such learners have often had high demands and expectations resourcing. of their programme and their provider, sometimes unreasonably Use learner voice and tutor so. They may expect a greater say in delivery methods, times feedback systems to provide and/or locations, and/or high-quality teaching, assessment early warning of learners processes, resources and support services. If these leaving or suspending their expectations are unfulfilled, they can be a significant cause of course commitments before poor learner retention. completing. While learners are right to have high expectations, these must be realistic. To keep learners on their programmes, you will need to find a balance between meeting these expectations Look at … and keeping them within reasonable limits. Induction is a Policy on funding processes: good time for staff and learners to discuss and agree initial expectations (on both sides), but you will need to monitor • Policy Overview and learner expectations and satisfaction levels throughout their Frequently Asked Questions, programmes. section 8 Some ITPs are making liability for the course fee explicit to the • Funding Rules 2013/14 (SFA, learner at enrolment (separate to the learner’s liability to the March 2013), pp 54-59 Student Loans Company for the Loan6). Improving the learner experience: If you are already used to managing payments by instalments, you may already have systems in place to recover course • LSIS Loans Toolkit 4: Quality fees if the learner leaves the programme early. However, and the learner experience course fee recovery is not a trivial undertaking and may prove disproportionately expensive to implement and follow through. 6 When a learner leaves a course prematurely, their Loan repayment commitment will be limited to the amount used for the time they were on programme – although they will have used up one of their four Loan entitlements. 11
Management of the Loans Bursary Fund The Loans Bursary Fund is aimed at helping vulnerable Loans- funded learners. It provides funding for: Do … Create or amend your Bursary • Discretionary Learner Support (DLS)-type activity for policy to specify the criteria hardship, childcare and residential support; you will need to and processes for allocating deal with this as Bursary payments to learners; funds from the Loans Bursary to • learning support-type activity (including exceptional learning support Loans-funded learners. support) for ‘in learning’ support (such as teaching assistants If you are a lead provider, it is or necessary adjustments under the Equality Act); you must your responsibility to talk to make sure that you keep sufficient funding for this purpose; your sub-contractors regarding distribution of the Loans Facility • provider area costs; calculated automatically and based on and Bursary Fund (only lead data in the ILR about where the learning takes place. providers have been allocated a Loans Facility and Bursary All providers with a Loans Facility have been offered a Loans Fund as they hold the ASB Bursary Fund allocation based on the size of the Loans Facility contract). (including a £500 de minimis). It is a separate allocation to the Loans Facility and can be claimed from the Skills Funding Monitor Loans applications Agency, using the ILR, through three7 individual fixed monthly during enrolment to estimate rates. If support needs go over the fixed monthly rate and you how many of those learners can provide evidence of the excess, you should claim for this may need access to your Bursary Fund for support. This excess through the Earning Adjustment Statement (EAS). will help you manage the Fund, You will need to retain evidence of all total expenditure prevent potential overspend on the learner where the excess claim process has been and will be particularly important for ITPs where enrolment takes used. If support needs exceed £19,000, then the costs over place throughout the year. £19,000 may be funded by the Skills Funding Agency through a separate national budget and you should talk to your relationship manager. Look at … The Loans Bursary Fund is distributed at the discretion of the provider and is not a learner entitlement. You will need Policy and budget management to keep your Bursary Fund allocation under review to ensure information on the Loans that it remains adequate for the support needs of the Loans- Bursary: funded learners you will be working with in 2013/14. This may • Funding Rules 2013/14 (SFA, be particularly relevant if you have a significant proportion of March 2013), pp 60-61 learners on Access to HE courses rather than learners who are supported by employers (where the employers might be • 24+ Advanced Learning expected to meet any employee support needs). Loans Budget Management (SFA, April 2013) Some ITPs are looking at ways to top up their Bursary Fund for reasons of equity and to attract learners. If you have concerns Creating a Bursary policy: that your allocation may be inadequate for the likely support • LSIS Loans Toolkit: Provider needs of your Loans-funded learners, you can request an practice supplement increase from the Skills Funding Agency following the process published in the briefing note, 24+ Advanced Learning Loans Budget Management (SFA, April 2013). 7 This is a change to the Funding Rules 2013/2014 (version 2) where it was stated that there would be two rates. See the announcement (28 May 2013) on the Skills Funding Agency website. 12
You will need to develop a policy managing payments from your Bursary Fund to Loans-funded learners. For some ITPs, this is new territory. Any policy will need to: • detail the application process – from the application form through to the assessment processes and decision-making (with reasons) – including processes for dealing with appeals and complaints; • outline the criteria for making decisions about awarding support – these should clearly reflect equal opportunities and diversity and any financial thresholds above which a Bursar application from a learner requires special consideration; • define processes that allow you to pay external support costs (e.g. childcare) direct to the service provider (such as a childminder). The Skills Funding Agency requires that: • all providers publish their methodology (including complaints procedure) for awarding the DLS element of the Loans Bursary Fund and that it is available to all learners; • evidence that the learning support element of the Loans Bursary Funding claimed is backed up by an assessment, that there is a planned programme of support included in the Learning Agreement, and there is evidence in the planned programme for providing additional support included in the Learning Agreement; • for learners whose support costs will be more than £19,000 in a funding year, prior agreement is obtained from your relationship manager. Financial implications 1 2 3 4 Rate your overall Loans readiness 1 = not ready; 4 = fully prepared 13
Data and information systems Loans are a form of government funding and part of the wider FE and skills offer. This means that your Loans provision is in scope for the calculation of success rates, ILR returns, minimum levels of performance, audit, and Ofsted risk assessment and inspection. Your MIS, data collection and reporting processes must be able to manage the additional data demands of managing Loans-funded learners. Your MIS will need to collect and submit the Loans-related data required by the Skills Funding Agency and the Student Loans Company. The evidence requirements of the Skills Funding Agency for Loans-related funding are detailed in the Funding Rules 2013/14. The Student Loans Company operates the Learning Provider Portal as their main channel of communication for Loans funding. If you are a lead provider, your organisation’s contract manager will have received an email in early March from the Student Loans Company requesting the nomination of two lead business contacts (a primary and a secondary). These people are responsible for the business-to- business administration of Loans. Your initial user access to the Learning Provider Portal will be via these nominated contacts. Feedback from ITPs who attended awareness-raising events on the Learning Provider Portal in February 2013 indicated that they found the Portal straightforward to use and they had few concerns about its operation. The first implementation phase of the Portal opened on 1 March 2013. This gave providers the opportunity to start familiarising themselves with the new system by viewing and checking the information held for their organisation and creating user access in time for the Applicant Information Service going live in June, when they will be able to view their learners’ application information. The final phase will be released in August 2013 when learner attendance confirmation and provider payment functions are implemented. If you haven’t already done so, appoint a Loans administration manager to take formal responsibility for monitoring the requirements of the Portal. It is important that you have external and internal data capture and transfer systems in place to ensure a smooth funding flow, avoid delays or breaks in payment, or overpayments that will need to be repaid. The following sections consider the key requirements in more detail. Data and evidence requirements Student Loans Company 1. When learners apply for a Loan to cover the fees for a course with you, so that they have all the information they need for their application, you must give them a Learning and Funding Information Letter (templates and guidelines have been provided by the Skills Funding Agency). The Letter must include: • your UK provider reference number (UKPRN); • the title of the learning aim and the learning aim reference number; • the name and code of the Apprenticeship framework level and pathway (if applicable); • the start date and planned end date; 14
• the fee charged to the learner; Do … • the maximum amount of Loan available for the learning aim or Apprenticeship framework. It is important that Make sure that your Learning you check the accuracy of these values using the Skills and Funding Information Letter follows the guidelines issued by Funding Agency published information, as inaccuracies will the Skills Funding Agency. lead to confusion for learners and additional administration to correct any information held as part of the Loan Meet Student Loans Company application with the Student Loans Company. notification deadlines; ensure that your systems can track 2. Once the learner’s Loan application has been approved and learner starts, attendances the learner has attended for at least two weeks (the initial and withdrawals (perhaps liability point), you must confirm this via the Portal in order to through your register system) trigger your payments. Payments will be delayed if you don’t and other changes in learner provide the Unique Learner Number (ULN) or if the learner circumstance. Your data hasn’t provided a valid National Insurance number. needs to be accurate and timely, especially where it is 3. Thereafter, attendance must be confirmed on a quarterly transferred between systems. basis to continue releasing payments. Attendance is Notify the Student Loans assumed in the months between quarterly confirmation Company promptly of non- and you must notify the Student Loans Company if a learner starters and changes in learner withdraws or takes a break in learning. circumstance to avoid overpayment and/or re-profiling. 4. The Student Loans Company will identify learners where attendance confirmation is required. This should be of particular help to those providers where learners start at different times. Look at … 5. Attendance can be confirmed for individual or multiple Information about the Learning learners at one time and via bulk import if you wish to do so. Provider Portal: 6. You must inform the Student Loans Company if a learner • Technical specifications has never attended (or leaves before the initial liability point). • Frequently Asked Questions The Student Loans Company will then cancel the learner’s Loan application (and it won’t count towards their overall • User guide and e-learning entitlement). They will also cancel applications for any training modules learners that don’t have an attendance confirmation by three • Materials from the months after the proposed start date. administration awareness 7. You must notify the Student Loans Company when a events (February 2013) learner’s circumstances change as this may have an impact Loans funding policy: on your payments as well as the learner’s entitlement and liability for the Loan. Examples include changes to • Funding Rules 2013/14 (SFA, learning aim details, changes to the Loan amount or the March 2013) pp 53-59 fee you are charging, learner withdrawal from the course, Policy on funding processes: early completion, or any breaks in learning (or subsequent resumption). • Policy Overview and Frequently Asked Questions, A change to the learning aim or an increase or decrease section 8, pp 28-30 in the Loan amount may result in an adjustment to your payments, and you will need to provide the learner with Guidance on the Learning and Funding Information Letter: another Learning and Funding Information Letter. Learner withdrawal or a break in learning will result in your funding • Guidance for colleges and payments for that learner being stopped. If a learner training organisations on completes their learning aim early, the Student Loans providing a Learning and Company will make a final payment to you for the Funding Information Letter remaining balance of the Loan. It is important that all (v3.0, April 2013) changes are notified quickly and accurately to avoid overpayments. 15
8. The Portal will provide statements of payments broken down by learner. Details of any overpayment recoveries will • Qualifications Learning and Funding Information Letter be stated where applicable. The Portal will also provide an template (v3.0) overall Loan position report which will give you a forecast of the value of Loans approved and your payment schedule. • Apprenticeships Learning and Funding Information The Skills Funding Agency Letter template (v3.0) 1. You will need to provide evidence of a completed Learning and Funding Information Letter for each learner in addition to the existing requirement for a Learning Agreement. 2. Information provided on the ILR for Loans-funded learners must match the information you give on the Learning Provider Portal. The 2013/14 ILR Specification includes the changes made to accommodate the introduction of Loans. 3. Learning aims financed by a Loan are recorded using Funding Model 99 (‘No Skills Funding Agency or Education Funding Agency funding for this learning aim’) with a Learning Delivery Funding and Monitoring Indicator code ADL 1 (in the Learning Delivery Funding and Monitoring Field). Otherwise, the data requirements are the same as for other non-funded learners. Data reporting and transfer between delivery partners If you are a lead provider, you will have been given user access rights to the Learning Provider Portal by the Student Loans Do … Company (see above). Your sub-contractors will not have been given access, as they do not hold an ASB contract. Establish clear systems for managing funding, data You may create user accounts for sub-contractors that grant reporting and transfer etc them access rights to the Portal. However, such access cannot between delivery partners, with be restricted to records relating to an individual sub-contractor, an identified lead partner taking overall responsibility. so a user account will give each sub-contractor access to the data records of all the partners across the delivery partnership. This may raise issues of confidentiality, so most lead providers are not providing such user accounts. Look at … Following feedback, the Student Loans Company is considering Support for conversations with introducing an enhancement to allow sub-contractor access to sub-contractors: the Portal to view their learners only under each lead provider. Until this is introduced, lead providers will have to extend • LSIS Loans Toolkit 3: their systems and capacity to process all the Loans data for Communication and collaboration – see the their partner(s). On the Portal, references can be assigned to ‘Contract checklist’ tool learners to identify those who are undertaking training with a sub-contractor or other trainer. So that delivery across the partnership is not interrupted, it is important that lead providers have early and comprehensive conversations with their sub-contractors to detail the necessary data transfer requirements and time constraints. 16
Managing learner and employer contributions to course fees Collecting learner payments/contributions for fees may be new territory for your organisation. Collecting employer contributions (such as from employers with apprentices) may be a more familiar process and what works well there could provide a model for extending your processes to collecting full or partial contributions from learners. Where you are managing multi-funded provision (part Loan funded, part learner and/or employer contribution) there will be the added complication of managing two or more funding Do … streams for one learner. Review your systems for If this is an area that you want to develop, there are several managing learner and employer questions you should consider: contributions to course fees. In particular, pay attention to • When will payments be made – up-front or instalments? options for multi-funding (where a learner may be part-funded • How/when will you invoice the employer/learner? by direct learner contribution, • How will payments be made – bank transfer, cash, cheque, employer contribution and a credit/debit card? Loan). • How will you track payments, especially if payments are by instalments or the learner is multi-funded? Look at … • How will you manage the VAT element of payments? Protecting the consumer during and after the implementation of • What will you do if the learner or employer defaults on their 24+ Advanced Learning Loans: payments? Will it be financially and administratively viable Final report (NIACE, June to pursue payment? 2012) • What are the implications for ensuring consumer protection and for your complaints policy? If you are offering credit to learners or employers (which is what you are doing when you allow payment by instalments), there may be legal implications as your organisation may need to be licensed for credit. Data and information systems 1 2 3 4 Rate your overall Loans readiness 1 = not ready; 4 = fully prepared 17
Communicating the Loans message The primary route for communications with learners about Loans is through the sector. The lack of a national awareness-raising campaign has caused concern amongst some ITPs. However, there is support for awareness-raising. • Information on Loans is available on the National Careers Service (NCS) website as part of their remit for providing individuals with IAG. • Some providers have used development funding (offered by BIS and the Skills Funding Agency to all training organisations with a Loans Facility as part of their ‘readiness programme’) for marketing and promotions. • Communication guidance and materials for provider use are available through the 24+ Advanced Learning Loans microsite (formerly the Student Loans Company’s Practitioner website). With the recent and extensive range of additions to the microsite, you may have found navigating the resources rather overwhelming. To help you to determine the value of each resource and identify the ones that will prove most useful for your needs, AELP has provided the document, Resources to help communicate the Loans message – a visual guide. This offers a visual walk-through of the resources available to support communication of the Loans message and contains hyperlinks to each resource. 18
Briefing staff Most ITPs will have already organised briefing sessions on Loans for their staff, probably providing a level of detail Do … appropriate to different job roles. So that they understand the Make someone responsible for strategic implications of Loans, board members, governors or providing an organisation-wide trustees should also have been briefed. information source on Loans for staff – perhaps via an internal From the start, it has been made clear that the necessity to staff newsletter, a dedicated inform learners about the option of Loans funding raises the area of the staff intranet or potential pitfall of providers being asked to provide financial through internal emails. Provide advice (or being seen as doing so). Your staff must recognise regular updates, especially that it is not their role to advise learners regarding financial during the first year of products. They should encourage learners to consider their own implementation – these can be circumstances and to look into all the options for paying for their informed by the BIS email alerts course before deciding on their financing method. Learners can and Skills Funding Agency web get free, impartial advice on managing their money from the alerts. Money Advice Service. Some ITPs have chosen to train only their IAG staff as they Look at … expect them to be the organisation’s experts when it comes to informing and advising learners and employers. Others have • 24+ Advanced Learning recognised that learners are likely to turn to familiar teachers, Loans microsite trainers or assessors for advice on funding their learning. They • LSIS Loans Toolkit 3: have, therefore, fully trained all their delivery, assessment and Communication and support staff (including those working with learners at Level 2, collaboration – see ‘Loans as they will influence progression) to ensure that nobody will staff training: topics overview’ provide incorrect or incomplete information, or step outside the bounds of the advice they should be giving. In practice, there • LSIS Loans Toolkits: Provider will be a scaling of knowledge, with managers and front-line practice supplement – see IAG staff likely to be the best informed. what other providers are doing If you haven’t already done so, train your staff now as you • Protecting the consumer need to be prepared for enquiries from learners interested during and after the in programmes starting from August 2013 onwards. If you implementation of 24+ are a lead provider, don’t forget to include staff from your Advanced Learning Loans: sub-contractors as it is your responsibility to ensure that the Final report (NIACE, June messages and information they give to learners and employers 2012) are high quality and consistent with that given by your own staff. 19
Marketing When you are thinking about marketing Loans to eligible customers – stop! Your focus should be on marketing the Do … benefits of learning at Levels 3 and 4 and on marketing yourself Make sure potential customers as a great training organisation. Loans funding is just one of the can differentiate your offer ways that eligible learners can access those benefits and your from that of competitors. promotional materials should raise awareness of Loans and not Demonstrate how you provide try to ‘sell’ them. value. With this slightly different focus, when you are producing your Make your materials available in promotional materials, look at: different formats, media styles and locations – people notice 1. the information you provide on your ‘product’ – learners using information in different ways at their own buying power will want more than just a description different times, so reflect this of the course content; they will want information on the in your marketing, and use as benefits that the course could provide (such as improve many different communication career prospects or earning potential) as well as course fees tools as possible (including and other course-related costs (e.g. equipment); social media). 2. your existing success rates and other performance data and consider whether these are high enough to attract potentially Look at … more discerning learners who are funding their own learning and, if not, how you could address this; make use of the FE Communicating the Loans Choices comparison website to promote the value of studying message to learners and with your organisation; employers: 3. providing jargon-free, clear and impartial information on all • Creating communications for learners options for financing the learning. • Text and FAQs for use in Don’t forget the value of face-to-face promotion, particularly in discussion with employers the workplace. Many ITPs are used to dealing primarily with employers when discussing provision, costs and payments. The • 24+ Advanced Learning removal of grant funding may require that you change emphasis Loans microsite from this traditional business-to-business relationship with • Funding Guide for Employers employers to a more business-to-customer relationship with (NAS) learners. • LSIS Loans Toolkit 3: Communication and collaboration – see the ‘Marketing plan’ • LSIS Loans Toolkits: Provider practice supplement – see what other providers are doing 20
Learner IAG, recruitment and enrolment You will already have robust and high-quality IAG and initial assessment systems in place to advise employers and Do … learners on the most appropriate options for learning to meet their particular needs. However, mature learners (and their Create a checklist for staff to make sure that IAG during employers) who are now financing their learning, perhaps for recruitment and/or enrolment the first time, may prove to be more discerning and so require is consistent from learner to more detailed guidance and discussion on their options. learner, is of high quality and that nothing is missed out. The withdrawal of grant funding also means that there will be an added dimension to your IAG – that of providing clear, impartial Make sure that IAG and support information on the options for funding the chosen learning. is available in the workplace and across all delivery partners. Once an appropriate programme has been identified, you will need to complete a Learning and Funding Information Letter (see the earlier section on data and evidence requirements) and give it to the learner – whether or not the learner has Look at … indicated that they intend to apply for a Loan. Accompany each Providing IAG: Letter with information leaflets on Loans and other options for funding as well as relevant course-related literature. To • Talking to learners about avoid the risk of learners denying that they have received this loans – a guide information, a growing number of ITPs are requiring learners to • 24+ Advanced Learning sign to confirm that they have received it. Loans microsite Where a learner has confirmed that they do want to apply for a • LSIS Loans Toolkit 3: Loan, improve follow-through rates by: Communication and collaboration • reviewing eligibility and document/information requirement checks with the learner to mitigate the risk of them not • LSIS Loans Toolkits: Provider following through on their Loan application due to difficulties practice supplement – see encountered once they have left the IAG advisor; what other providers are doing • offering the use of online facilities for Loan applications for those learners who do not have easy access to a computer Referral sources: – you won’t want to risk losing them just because they were • National Careers Service unable to complete the application process; • Money Advice Service • making sure that the learner knows: • National Apprenticeship - how long before the start of a course they must make their Service Loan application – the typical time for the application to be processed by the Student Loans Company is expected to Guidance on the Learning and Funding Information Letter: be 4-5 days if the application is submitted online with valid UK passport details, and 2-4 weeks otherwise (as long as • Guidance for colleges and the form is completed correctly); training organisations on providing a Learning and - how to track its progress; Funding Information Letter (v3.0, April 2013) - how to complete enrolment once the Loan is approved; • Qualifications Learning and - what to do if they change their mind about either the Loan Funding Information Letter or the course. template (v3.0) The result of all the above will mean that IAG time per learner • Apprenticeships Learning will increase significantly. You should make sure that you can and Funding Information resource this in terms of staff and space, particularly where Letter template (v3.0) you are operating from employer premises where your front- line staff may need to have ‘payment’ discussions directly with learners as well as with the employer. 21
While well-briefed and trained front-line staff are essential to an effective IAG service, some potential learners will prefer to make initial contact online (via your website and/or social media) or by telephone. You will need to make sure that knowledgeable staff are available to deal with this online and telephone contact. Ensuring quality and consistency across delivery partners Lead providers If you are a lead provider, it is your responsibility to ensure that your sub-contractors for Level 3 and/or 4 provision understand and fully participate in the deployment of Loans. Early contact with your sub-contractors is important as preparing for Loans readiness should be a collaborative process if quality and consistency are to be achieved. The Loans Readiness Survey indicated that a significant number of sub-contractors had not heard anything from their lead partners. This is of considerable concern as Loans have already gone live. Work with your sub-contracting partners to ensure that you are all providing accurate, consistent messages and support to learners regarding all options for fee paying. As the lead provider, you bear ultimate responsibility for all complaints from learners about Loans-related IAG even though you will not have the same control over a sub-contractor’s staff and processes as you do of your own (despite the due diligence aspect of their contract). Minimise potential problems by training staff from your sub-contractors with your own staff. With your sub-contractors, clarify exact responsibilities in relation to the transfer and processing of data on Loans-funded learners. Bottlenecks can be caused at either end of the data exchange chain. Don’t let your sub-contractor’s data needs Do … be subsumed by your own. Aim to respond in a timely manner so that the learner experience is consistently good no matter Talk to your delivery partners which delivery partner they are with. to arrange early and regular Loans briefings and training Sub-contractors sessions for all staff across the partnership. Include If you are a sub-contractor, it is your responsibility to make partners responsible for sure that you are clear about the expectations of your lead Level 2 provision, as these are provider(s) and the implications of Loans funding for your important for providing Loans contracts. So that you can prepare for Loans implementation IAG messages to adult learners collaboratively, you, too, should be working to arrange briefing who may later progress to Level 3 provision. and contracting discussions with your lead provider. Demonstrate that you can maintain the same quality of delivery and customer support for your Loans-funded provision as you Look at … do (or did) for your grant-funded provision. Supply Chain Management Recognise that you are unlikely to have direct access to – A good practice guide for the Learning Provider Portal (at least in the near future), so the post-16 sector (AELP, make sure that you understand the implications of your lead LSIS, AoC, January, 2013) provider(s) dealing with all the data requirements of the Student 22
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