Learners repeating a previously achieved learning aim
A funding monitoring report identifies records and patterns that DfE wants providers to investigate and be able to explain. Appearing on one does not by itself mean a record is wrong. Many flagged records are correct and simply need their evidence produced; others turn out to need a correction.
Where this comes from
Every word below is DfE’s own, read from the published guidance on 19 September 2026. Nothing in this section was written by FEFunding.
Summary
We do not fund learners to repeat a regulated qualification they have already achieved.
This does not apply to:
- English and maths aims delivered through the ASF
- GCSEs where the learner has not achieved grade 4 or above
For apprenticeships, you must not use funding to pay for training for knowledge, skills and behaviours the apprentice has already attained.
Funding streams reviewed
- adult skills fund (formula-funded provision)
- apprenticeships (from 1 May 2017)
What you need to do
You must code aims which are not eligible for funding as Funding model code 99 (Non-funded (includes indirect DfE funding)). If the aim is continuing from a previous year, you will need to follow the provider support manual guidance on correcting aims with an incorrect funding model after the R14 hard close submission.
For apprenticeships, you may need to review and renegotiate the price and off-the-job training hours, ensuring that minimum duration requirements can still be met.
What we will do
We will recover any funding overclaim for errors that remain in your R14 data return.
Changes from previous funding year
From this year, if an apprenticeship English or maths aim triggers both FRM01 and FRM13, the aim will only appear in your FRM13 report. The same aim will no longer appear on both reports.
What this means in practice
This section is FEFunding’s explanation, not DfE’s wording. It was drafted with AI assistance against the official guidance above. Its approval is pending confirmation, so it is not yet shown as reviewed by a person. Where it differs from the Department’s own words, the Department’s words are the authority.
In plain English
This report lists learners who are being funded to do a qualification they have already passed. DfE does not pay twice for the same regulated qualification, so it asks you to look at each one and say what is going on. There are exceptions, and a learner appearing here may well be one of them.
Based on FRM01 Summary.
Working knowledge
The report identifies funded aims where the learner already holds the regulated qualification the aim leads to. DfE names three exceptions in its own wording: English and maths aims delivered through the Adult Skills Fund, GCSEs where the learner has not achieved grade 4 or above, and it states separately that for apprenticeships you must not fund training for knowledge, skills and behaviours the apprentice has already attained.
Based on FRM01 Summary.
Technical detail
Prior achievement of the regulated aim is checked against funded delivery on the same aim reference. Where the aim is genuinely not eligible, DfE's instruction is to record Funding model code 99, non-funded, rather than to delete the aim. For an aim continuing from a previous year, DfE directs you to the provider support manual guidance on correcting aims with an incorrect funding model after the R14 hard close. For apprenticeships it notes that price and off-the-job hours may need renegotiating, provided minimum duration can still be met.
Based on FRM01 What you need to do.
Why this report exists
Public funding is not intended to pay for a qualification a learner already holds. The report gives DfE a way to see repeat funded delivery across providers and ask about it.
Based on FRM01 Summary.
What DfE is identifying
Funded aims for a regulated qualification the learner has previously achieved, excluding the cases DfE lists as out of scope.
Based on FRM01 Summary.
Does appearing here mean something is wrong?
No. It means the pattern needs explaining. DfE itself lists exceptions where repeat delivery is funded, and prior achievement data is not always complete or correct, so a flagged aim is frequently legitimate and simply needs its reason recorded.
Based on exception-is-not-error; FRM01 Summary.
Legitimate reasons for appearing
- The aim is English or maths delivered through the Adult Skills Fund, which DfE states is not in scope.
- The aim is a GCSE where the learner has not achieved grade 4 or above, which DfE states is not in scope.
- The prior achievement held against the learner belongs to a different qualification with a similar title, or was recorded against the wrong learner.
- The learner holds the qualification but the apprenticeship requires knowledge, skills and behaviours they have not attained, which is a judgement the provider should be able to evidence.
Based on FRM01 Summary.
Data or process problems that can cause it
- Prior attainment was not checked at enrolment, or was checked and not recorded.
- The aim was enrolled on the funded default rather than being recoded to funding model 99 once prior achievement was known.
- A prior achievement discovered after enrolment was corrected in the student record system but the funding model on the existing aim was never changed.
Based on mis-generates-the-ilr; fund-model-selects-the-rules.
What to check first
- Confirm the learner genuinely holds the same regulated qualification, not one with a similar title.
- Check whether the aim falls within an exception DfE names: ASF English or maths, or a GCSE below grade 4.
Based on FRM01 Summary.
Working through it
- Identify the aim and the prior achievement the report is matching against.
- Confirm the prior achievement is real, belongs to this learner, and is the same regulated qualification.
- Check the aim against the exceptions DfE lists in the summary.
- If the aim is out of scope of funding, establish when that became known: at enrolment, or later.
- For an apprenticeship, establish whether the knowledge, skills and behaviours being delivered are genuinely additional to what the apprentice already holds.
- Decide whether the record is correct and explainable, or whether the funding model needs changing.
Based on FRM01 Summary; FRM01 What you need to do.
ILR fields involved
- LearningDelivery.LearnAimRef
- LearningDelivery.FundModel
- LearningDelivery.ProgType
- LearningDeliveryFAM.LearnDelFAMType
Based on fund-model-selects-the-rules.
Related ILR validation rules
- PriorAttain_01
- R_131
Based on PriorAttain_01; R_131.
Related PDSAT reports
- A-501
- A-514
Based on A-501; A-514.
Returns this relates to
- R14
Based on FRM01 What we will do.
Funding implications
DfE states it will recover any funding overclaim for errors that remain in the R14 data return. Aims corrected before R14 therefore do not reach recovery, which is why this is worth working through in year rather than at year end.
Based on FRM01 What we will do.
Audit and assurance implications
For any aim you keep as funded, the question an auditor asks is why it was eligible despite the prior achievement. That answer is much easier to give if it was recorded at the time rather than reconstructed afterwards.
Based on evidence-must-be-contemporaneous.
Evidence to look for
- The prior attainment check carried out at enrolment, and what it returned.
- The certificate or awarding organisation record behind the prior achievement, where the learner disputes it.
- For an apprenticeship, the initial assessment showing which knowledge, skills and behaviours were already attained and which were not.
Based on evidence-must-be-contemporaneous.
If the data is wrong
- Where the aim is not eligible, record Funding model code 99 as DfE instructs, rather than removing the aim.
- Where the aim continues from a previous year, follow the provider support manual guidance DfE points to for correcting an incorrect funding model after the R14 hard close.
- For an apprenticeship, review and if necessary renegotiate the price and the off-the-job hours, making sure minimum duration requirements can still be met.
- Make the change in the system that owns the data and regenerate the ILR, rather than editing the return.
Based on FRM01 What you need to do; correct-the-source-not-the-return.
If the data is right
- Record which exception applies and what was checked, against the learner, so the answer survives staff changes.
- Keep the prior attainment check and its result where it can be retrieved without reconstruction.
Based on change-evidence-matters.
Stopping it recurring
- Make the prior attainment check part of enrolment rather than something done afterwards, so the funding model is right the first time.
- Where prior achievement is discovered later, make changing the funding model part of the same task as updating the learner's record.
Based on mis-generates-the-ilr.
Questions an MIS manager should ask
- How do we check prior attainment at enrolment, and where is the result recorded?
- When prior achievement is found after enrolment, who changes the funding model on the existing aim, and how do we know it happened?
- Which of the aims on this report are the exceptions DfE names, and which are not?
Based on mis-generates-the-ilr.
Questions a finance director should ask
- How many of these aims do we expect to still be funded at R14, and what is our basis for keeping them?
Based on FRM01 What we will do.
What a good answer sounds like
- A good answer names the exception that applies, or says plainly that the aim should not have been funded and when it was recoded.
- A weak answer is that the learner needed the qualification again, with nothing recorded at the time to show why.
Based on change-evidence-matters.
Related Academy learning
- apprenticeship-funding-mechanics
- enrolment-quality
- evidence-principles
Based on fund-model-selects-the-rules.
Funding streams this report reviews
FRM01 in other funding years
Working through it in your own system
- Read the official wording for this report and note exactly which records it identifies.
- Find those records in your own data using the fields the report names.
- For each one, decide whether the record is correct and simply needs its evidence produced, or genuinely wrong.
- Trace a wrong record back to the entry in your source system that produced it, rather than to the file it appeared in.
- Correct it at that entry, regenerate and resubmit.
- Keep the evidence and the reason for the change together, so the record is explainable at audit.
The Academy has no verified supplier guidance for this report yet. Menu locations differ between product versions and between colleges on the same version, so we do not publish navigation we have not confirmed. The steps above are what has to be true in the data, which is the same in every system.
If the record does turn out to be wrong. Correct the record in the system where the data is entered, then regenerate the ILR file and resubmit it. Editing the generated file directly removes the symptom and leaves the cause in place, so the same record returns at the next submission with nobody expecting it. Keep a note of what was changed and why: that note is what makes the correction explainable later.