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
Advanced Learning
     Loans Guide
A guide to 24+ Advanced Learning Loans
       for independent training providers
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
Advanced Learning Loans Guide - A guide to 24+ Advanced Learning Loans for independent training providers
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
You can also read