Apprenticeship off the job training: top tips for compliance

Posted by Carla Martinho on August 25, 2022

Off the job training (OTJ) has been a hot topic for apprenticeships providers for a few years and was one of the major changes made to the Apprenticeship Funding Rules for 2022/23.

In the newest change, from 1 August 2022 newly recruited full-time apprentices need to receive a minimum of 6 hours off the job training per week.

In this blog Carla Martinho, Tribal’s Head of Data Management Services, shares her top tips for complying with the rules for off-the-job training hours.

1. Have a detailed delivery plan for all your off-the-job training, not just the knowledge/theory delivery. This will help you to show auditors (and employers and learners) how the OTJ will be delivered, as well as how it relates to the content of the Standard which it must do to be eligible.

2. Plan for more than the OTJ minimum of 6 hours average per week for full time employees: Otherwise, if you have made a mistake in your calculations, or any activity is deemed ineligible by the auditors, this could take you below minimum and make the entire value of the apprenticeship subject to being clawed back. Having a delivery plan which takes you over the 6 hours per week minimum gives you some margin to mitigate against this.

3. Monitor participation progress against the OTJ plan: OTJ is not just about counting hours racked up to get to the minimum (which you should be tracking as a matter of course). You need to track participation and progress, so make sure this is included in any progress reviews. The rules around progress reviews have changed to reflect this requirement so check your template against section P59-60 of the funding rules).

This also helps you to identify additional support needed if they’re not progressing (which Ofsted will be looking for). At audit it enables you to evidence progress made by both on-programme and withdrawn learners, so avoiding risks of clawback based on insufficient evidence of learning for the duration of the learner’s time on programme.

4. Check that OTJ is only logged during working days/hours: If apprentices are logging OTJ learning of - for example, 30 hours to write an essay against one date, not only is this not possible, it also means that auditors have no evidence that the OTJ hours were delivered during working hours - which they must be to be eligible. Check with the learner – should it have been recorded as 5 hours across 6 different dates?

5. OTJ hours review before EPA gateway: Do a thorough review of each learner’s OTJ records before putting them through EPA gateway as any OTJ learning must be done during the practical period, so can’t be after the gateway. The pre-gateway check is your last opportunity to check that the apprentice has received the planned OTJ hours (and at least the 6 hours per week minimum), to avoid any risk of clawback at audit.

Is all the activity recorded eligible, delivered during working hours and directly relevant to the Standard? Also check that the same practical tasks haven’t been included repeatedly, so are no longer off-the-job learning.

For example, practicing a skill like use of massaging techniques and shampoo and conditioning products shouldn’t be repeated weekly for the duration of the apprenticeship as it becomes work-based activity once the apprentice has grasped the skill.

6. If you have an under-delivery of OTJ check the negotiated price: If you have under-delivered the volume of OTJ against planned hours (but still meet the minimum), this is acceptable within the rules as long as you produce a statement signed by the employer agreeing this.

However, be careful that the reasons given for under-delivery in the statement aren’t that the learner progressed more quickly than expected because they knew more than indicated in their initial assessment. Auditors would expect to see a reduction on the original negotiated price on that basis.

For more information:

To learn more about the changes to off the job training, click here

Watch Tribal's Funding Rules webinar here

For the full rules: Apprenticeship funding rules - GOV.UK (www.gov.uk)

For template and more guidance on off the job training: Apprenticeships: off-the-job training - GOV.UK (www.gov.uk)

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