Successful audits depend on training providers being confident in the accuracy of their funding claims and able to support their decisions with robust evidence. In this webinar, Karl Bentley, Director of Funding Assurance at Validera, guides us through the key steps for effective DfE audit preparation.
What you’ll learn:
- An introduction to the DfE assurance approach, including considerations and tips for funding assurance reviews, alongside insights into timescales, sample sizes and next steps.
- Three key themes from 2024/25 reviews and work completed in 2025/26, looking at initial assessment and recognition of prior learning (RPL), EPA costs and Off-The-Job Training (OTJT) plans and evidence.
- How Aptem supports your DfE audit preparation process, particularly in relation to the three key themes that have been identified. Download our guide to learn more.
If you have any questions, please get in touch with us at hello@aptem.co.uk.
Answering your questions
Due to the large number of attendees, we weren’t able to answer all questions during the webinar. Karl has kindly provided his Q&A responses below. These answers are intended as general guidance only – organisations should seek independent, formal advice where specific compliance decisions are required. We hope you find these useful.
Q. Is it possible to have a copy of the Internal Control Questionnaire that is used now. Many thanks.
A. It’s for DfE to publish, not me.
Q. Delivery to own employees – what evidence is required for cost calculation to satisfy PDSAT checks. What if NO cost reduction?
A. We need to see your costings (not price breakdown) to confirm no profit is being made – so number of hours taught over the programme on an average hourly rate etc. is what we’re looking for. If there’s no reduction we need to confirm that your costs effectively mean you make no surplus/profit and it’s possibly costing you to deliver provision to your own staff.
Q. If PMR payment amounts do not exactly match co-investment £ is completion payment withheld?
A. It’s my understanding that if all the co-investment has not been recorded in the PMR1/2 field of the ILR the completion payment will be withheld.
Q. Who will be a pre or post R14 audit?
A. Pre R14 is completely random. Post R14 is determined by DfE.
Q. Re: TNP2 EPA fee changes – it is acceptable to adjust the TNP1 to account for the change so that total price remains the same. Would we need a new Training Plan in that instance?
A. Yes, it is – but the rebalance needs to be agreed with the employer.
Q. What logos need to be on paperwork based on all the new updates?
A. Suggest asking the Helpdesk – we’ve had no steer.
Q. Where do we find the RPL calculator from the DfE?
A. There’s a formula that needs to be applied, no calculator has been produced.
Q. In the financial handbook, ‘appointment of external auditors’ section 5.7-5.9, is this where an external auditor like yourselves would come in and do an audit or is this a separate requirement. We are being quoted up to £12k for an audit and we are also paying someone to do a ‘mock’ DfE audit?
A. Sections 5.7-5.9 relate to external auditors who sign off the accounts. However, external auditors may undertake some funding assurance work as part of the accounts sign off to confirm funding is eligible. Funding assurance – the work I do is separate and is either commissioned by the client. We agree the scope of work and work under the direction of the client, but following the DfE assurance approach to replicate any possible outcomes that could arise in an actual DfE review. So they are two different activities, but may have some overlap.
Q. Are we able to ask for a specific audit firm if we get notified?
A. Not that I’m aware of. And if the audit firm has had a relationship with you in the last three years they are conflicted out.
Q. How do you expect RPL to be applied on regulated standards such as Registered Nurse where the full curriculum needs to be taught unless there is APL?
A. If the learner has no formal qualifications that need to be considered then there is no RPL.
Q. If a review is done in 25/26, is it only learners who completed or are in learning within this year that would be reviewed?
A. It’s whatever is in the ILR during 25/26. Only a funded learner could be selected for sample, but out of funding learners can be reviewed via the PDSAT, such as learners in learning beyond planned end date, functional skills achieved in a prior year but still present or restarted regulated aims, functional skills only, where no funding adjustment has been applied.
Q. For post R14 audits, is there consideration for PDSATs being down as they often take months to become live as the new contract year starts?
A. No – as we’re auditing 25/26 so the data is locked.
Q. Would an auditor accept old OTJ logs that may have been poor due to initial introduction, e.g. 4 years ago. However the latest OTJ entries are compliant and look the part. Or should the provider be making an effort to improve old OTJ logs from 4 years ago?
A. If the logs are compliant then not an issue. If they lack key information such as what was learnt or there isn’t an indication if the activity took place within contracted hours then expect to be challenged – you can go back to the learner and employer for clarification if needed.
Q. Do we need to have a H&S document signed and also a separate apprentice agreement per learner to be signed?
A. It’s good practice to, but funding assurance reviews will only focus on the agreement with the employer and the required funding documents such as the Apprenticeship Agreement and Training Plan.
Q. Do all OTJ logs need to be individually reviewed by reviewers/skills coaches/members of staff and employers through an approval system (dated and signed) to be compliant?
A. Not that I’m aware of.
Q. If the provider has gone through the audit with a ‘Satisfactory’ outcome, when roughly can they expect the next audit?
A. There’s no timeframe – it could be within a few years or nothing for over ten years.
Q. Question regarding revising original planned end dates (practical period and programme planned end date) on return from break in learning: Is it allowed to extend the original PED beyond the number of days the apprentice was on BIL, if the provider knows that the revised planned end dates that ILR dictates won’t be an accurate reflection of the time of learning the apprentice will require upon return from break? Will this trigger an audit error? e.g. apprentice was on BIL for 120 days, but provider extends the new planned end dates by 240 days.
A. Yes – you can extend the programme if it’s in the best interests of the learner and the employer agrees. This will reduce the value of your OPP as the residual funding is being paid over a longer period. It won’t trigger a funding error provided the learner is still in learning.
Q. Do DfE audits always focus on the current academic year, or do they focus on the last completed academic year? So, if selected for audit pre-R14, will they be looking at the most recent 2025/26 ILR or the R14 2024/25 ILR?
A. For this year the pre R14 audits will focus on 25/26, post R14 audits will also focus on 25/26 – the difference being that for post R14 audits the ILR cannot be corrected, so any funding errors will be subject to recovery through different routes.
Q. Would a spreadsheet that the auditors use for their audits of providers be available to providers for their own internal audits?
A. Yes – it’s available via the PDSAT software. If you upload your FIS CSV zip file (you’ll need to run the ILR through FIS first) you can access the sampler. If you run a sample, you’ll be able to access the working papers.
