A fear of funding clawbacks is putting providers off accessing government support for apprentices with additional learning needs – raising the risk of a student giving up and saddling trainers with extra costs.
All education and training providers have a duty under the 2010 Equality Act to make reasonable adjustments for those with learning difficulties so they are not placed at a “substantial disadvantage”.
But experts blame complex funding rules and “constant fear” of clawbacks that means in four out of five cases providers avoid applying for help.
The main source of funding, the additional learning support (ALS) fund, is a fixed £150 per month intended to pay training providers for adjustments such as additional assessor visits and specialist equipment.
Government spend on support funding for apprenticeships rose from £32 million to £33 million from 2020-21 to 2021-22. But the spend from 2022-23 onwards does not appear in Education and Skills Funding Agency accounts after accountability for apprenticeships was transferred to the Department for Education.
Funding rule changes in August were intended to make the process of claiming ALS cash easier and provide new functional skills flexibilities for apprentices with SEND. But these tweaks may not have gone far enough.
Tim Chewter, Strategic Development Network’s director of business development, says providers “often lack confidence” in claiming support.
“The government has placed a greater emphasis on widening access to apprenticeships, and yet apprentices with additional learning support needs are more likely to drop out before completion,” he adds.
Unidentified learning difficulties
ALS was made harder to access in 2021 when the Tory government insisted providers perform a further assessment to claim the funding.
But learning needs are not always identified. The share of apprenticeships starting with an “unknown” number of learners with learning difficulties and disabilities rose year on year from 2020-21 to the first three quarters of 2023-24, from 3 to 3.64 per cent.
Meanwhile, the percentage of apprentices with confirmed learning difficulties and disabilities rose from 11.8 to 15.6 per cent.
The true proportion is believed to be higher.
Government research suggests around 20 per cent of people aged 16-64 have a disability or learning difficulty, so around 5 per cent of those doing apprenticeships could have unidentified needs.
Technology resource FE Tech found around 35 per cent of all screened learners qualify for additional learning support. “Without the power of learning technology, we would never have identified them all,” says its chief executive, James Earl.
Recent government rule tightening means from August a learning support assessment must now be included within initial assessments, with funding at risk if this is not evidenced.
Easier to drop out
Chris Quickfall, chief executive of Cognassist, a digital platform which assesses learning needs, considers it a “disgrace” that whereas university students would almost inevitably get adjustments to support their learning needs, the same has not been true for apprentices.
Only half of apprentices with learning difficulties or disabilities (and the same proportion with ‘unknown’ difficulties) achieved their apprenticeship in 2022-23, compared to 55 per cent of those without identified needs.
Caroline Fillery, managing director of Support Connect, which helps apprentices with learning difficulties access support, believes the lack of help for those with learning needs is driving low completion rates. “It just creates mass anxiety, and the easiest option is to drop out,” she says.
Clawback concerns
To access ALS funding, providers must show evidence that reasonable adjustments resulted in a monetary cost, which is not always easy to prove.
Several large cases of funding clawbacks by the Education and Skills Funding Agency have spooked some providers from applying for it.
Lifetime Training must repay at least £5 million, contributing to its after-tax losses climbing from £9.2 million to £21.1 million in the 18 months to July 2023. Lifetime’s chief executive David Smith says rules around what evidence is required are “not as obvious” as they should be, particularly when drawing from more than one fund.
“That is clearly leading to challenges within the market because I’m aware that some people don’t claim at all,” he says.
Activate Learning’s lead apprenticeship coach Suzanne Read wrote for the Education Training Foundation last year saying the group, which runs five colleges, had to repay £350,000 to the ESFA in 2022-23 for ALS support.
And although Activate had a “high number” of performance coaches providing ALS support “at a high level”, since then it has “not been claiming the available ALS funding to support us in this delivery”. That support was worth £450,000 a year.
A survey of the group’s apprenticeships team found “not only are we not claiming the funding to which we are entitled, but that overall, we are not confident the support we are giving to our learners with ALS needs is sufficient or consistent.”
The auditor RSM’s risk assurance director Lisa Smith says one of the most common clawback risks is that initial assessments do not “clearly demonstrate” the support need is linked to whether the learner can achieve their learning goal.
This is “generally” where needs are “related to mental health concerns”, and the reasons for it have “not been clearly articulated”.
Simon Ashworth, deputy chief executive of the Association of Employment and Learning Providers (AELP), says: “Lots of providers have had audit issues around the interpretation of how ALS is applied [which has] always been a bit of a grey area.”
Instead, many providers offer additional learning support “for free”.
Quickfall says although providers’ quality teams are normally keen to access ALS funding to improve retention and attainment, “quite often their finance team have heard about clawbacks and effectively kibosh that”.
He believes part of the problem is the DfE’s “loose” rules around the issue were “interpreted very differently by some auditors”.
Support Connect chief executive Matthew Heathman claims it is “101 per cent compliant” with the rules, and all clients “pass their audits with clean bills of health”, but adds: “We’re still constantly having to persuade providers who have such a constant fear.”
Travel agent Hays Travel has done assessments through Cognassist for a year but is still yet to claim ALS funding. Instead, it has been “focusing efforts on upskilling our learning and development coaches and making sure we’ve got all the robust evidence in place first”, says apprenticeship delivery manager Natasha Heslop.
Too busy to log evidence
Askham Bryan College, a specialist land-based college in York, only claims ALS for a handful of its 300 apprentices.
Its apprenticeship administration co-ordinator Julie Wilson admits there is “potential to put more on it” but staff have “shied away” from applying because “they’re busy teaching, and weren’t prepared to keep up with compiling the evidence regularly”.
Head of apprenticeships Ritchie Bywater says the college provides the extra support needed for at least 20 apprentices.
“We’re going above and beyond. We’re just not transferring that support into claims because of difficulties in gathering and recording the evidence.”
He blames this partly on the fact his college only employs support staff in term time, leaving them “on the back foot” in finding people who understand complexities of the apprenticeship system.
“It then falls on course managers [to evidence claims] and alongside the standards, enrolments and the end-point assessment, the recording of evidence falls down the priority list.”
He says the required evidence can be “hard to quantify” – for example, while a Teams call can be recorded and saved, a phone call has to later be “typed up” while support provided during a class has to be written up with “the impact that it’s had, and showing what is different for that learner compared to other learners”.
David Lockhart-Hawkins, a specialist on ALS for the Strategic Development Network, says the “barrier” to claiming funding for providers is “often a lack of confidence in their systems to generate evidence” but believes that evidence “should naturally follow” when a “really good support plan” is put in place.
Relaxing the rules
The government has not revealed how many apprentices with identified learning needs are being funded through ALS. But in recognition of prevailing challenges, this summer it reduced the frequency of the required learning support reviews from monthly to at least every three months.
It also clarified that the further, detailed learning support assessment can take place at any time during the apprenticeship rather than just at the start, which Ashworth says helps when an apprentice’s needs are spotted after they’ve started their course.
Meanwhile, Association of Colleges senior policy manager Claire Barker says that some colleges may have to procure more specialised and detailed assessments externally, which comes at a cost that cannot be claimed back through ALS
The government is also now allowing apprentices with learning difficulties to work towards lower-level functional skills.
Whereas previously only those with a pre-existing education health and care plan (EHCP) or statement of learning difficulties assessment (LDA) could work towards a lower level of functional skills in English and maths at entry level three, now that flexibility is extended to anyone assessed as having a learning difficulty.
Quickfall believes this has “really big” consequences, as functional skills are a “key reason why apprentices don’t end up completing their course”.
That’s especially true since 2019, when functional skills were reformed in ways that many providers say made them harder. The achievement rate dropped between 2020-21 and 2022-23 for apprentices with learning difficulties and disabilities from 55 to 51 per cent.
Other funding sources
For monthly costs exceeding £150 there are two other funding streams: excess learning support, for when reasonable adjustments cost less than £19,000 a year (claimed through the earnings adjustment statement), and exceptional learning support for costs over that amount.
Barker says colleges are “reviewing what funding is available as there are now more apprentices that need more support”. There is some hesitancy, however, due to past audit concerns.
Support Connect was founded in 2000 by Fillery and Heathman to help providers tap into that funding, with the pair having previously specialised in helping university students access the disabled student allowance.
Fillery estimates that when they started, less than one per cent of providers were accessing government funding to support apprentices with learning needs; now, she believes around 20 per cent of providers claim what they’re entitled to.
“Heathman is critical of providers “trying to keep” support costs under the £150 monthly cap to target ALS funding when many apprentices with learning difficulties “naturally need” over that amount, often requiring around £4,000 a year of support”
“Everyone’s trying to squeeze it into that little block and wonder why it’s not working. It’s because it’s not enough money,” he says.
Needs are growing
Although government funding is underutilised, the support needs of apprentices appear to be growing along with increased awareness of neurodiversity. Cognassist’s research found the proportion of people who think they have a neuro-difference was less than 10 per cent of those aged between 50 and 55, but up to 40 per cent for those aged 20 to 25.
Aptem’s analysis of government data found that dyslexia was the most common need for apprentices, growing by one-sixth to 5.3 per cent from 2020-21 to 2022-23. Mental health difficulties only rose from 1.5 to 1.8 per cent in that time.
There was variation across apprenticeship standards with the highest levels of learning difficulty being for apprentices on early years practitioner and hairdressing professional standards (both 25 per cent).
Employer engagement
Quickfall is optimistic that learning support for apprentices is improving. He sees “a lot of employers”, particularly large public companies, now putting neurodiversity components into tender packs for training programmes. The training provider then has to ensure their employees are not discriminated against during their training.
But while creative and media companies are keen to embrace equality and diversity requirements, retail employers still “tend not to”.
And individual departments within a corporate entity may vary; a head office may “live and breathe” equality and diversity culture but not their warehousing team.
Hays Travel is keen to support all its apprentices with learning needs. Of just under 400 apprentices who started with the firm this summer, one in eight had a declared learning difficulty when they signed up. But after Cognassist assessments, another 100 (25 per cent) required a further needs assessment.
Heslop says often the assessments pick up learning needs the apprentice already suspected they had.
Apprentices are then “encouraged” to complete a module a month on Cognassist as part of a support plan drawn up with their learning and development coach.
But while some apprentices are “happy” to accept the “extra layer of support, others don’t want it”.
Or in laypersons terms…
ALS funding has been increasingly used as a revenue stream because of the underfunding of core programmes. Some providers doing this, by operating in the grey areas created by the DfE not precisely defining what a learning difficulty/disability is, have been caught out.
The upshot being that underfunding, bad systems design and poor policy definition by the DfE, coupled with weak leadership and poor decision making across the provider base has created mistrust within the skills system.