Continuing or completed learning aims that are now reported as withdrawn on or before 31 July of the previous funding year
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
If a learner is continuing learning at the final R14 collection at the end of the year, but you record in the subsequent ILR year that they should have left in the previous ILR year, you may have earned funding that you need to repay.
This report identifies funding that may be recovered because a withdrawal was reported late. If the error extends into multiple previous years, the recovery could exceed the amount shown as we only show the previous year’s funding.
Funding streams reviewed
- adult skills fund (formula-funded provision)
- apprenticeships (from 1 May 2017)
- advanced learner loans
What you need to do
In previous years we have asked you to pay back funding related to FRM27 through the EAS. However, we will now contact you separately after the R14 return to recover the funding that relates to FRM27.
You do not need to take any in-year action for this report.
Do not submit repayments for FRM27 through the EAS.
What we will do
We will recover any funding overclaim for errors in your data after the R14 return. As this error will relate to previous funding years, we will not process this recovery through final claims and reconciliation processes for the current year, but we will account for previous years’ reconciliation processes.
Changes from previous funding year
We have changed the way you pay back funding relating to this report, see the updated information in the section ‘What you need to do’ below.
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
At the end of last year you told DfE these learners were still going, or had finished. This year you have said they actually left on or before 31 July last year. Because last year's funding was worked out on the basis that they were still there, some of it may need repaying. The important thing to work out is whether the new leaving date is right.
Based on FRM27 Summary.
Working knowledge
The report compares a learner's status at the previous year's final R14 collection with what the current year's ILR now says. Where an aim was continuing at R14 but is now reported as having ended on or before 31 July of the previous year, the funding earned for that period may be an overclaim. DfE notes that where the error extends into more than one previous year, the recovery could exceed the amount shown, because the report only displays the previous year's funding.
Based on FRM27 Summary.
Technical detail
The trigger is a backdated actual end date crossing the funding year boundary, against an aim that carried a continuing or completed status at the previous R14. The recovery mechanism changed from 1 August 2026: DfE previously asked for repayment through the earnings adjustment statement and now states it will contact you separately after the R14 return. DfE is explicit that no in-year action is required and that repayments for FRM27 must not be submitted through the EAS.
Based on FRM27 What you need to do; FRM27 Changes from previous funding year.
Why this report exists
Funding for a learner is earned while they are in learning. If a withdrawal is recorded after the year has closed, the previous year's funding was calculated on a position that turned out not to be true, and there is no other route by which DfE would see it.
Based on FRM27 Summary; final-return-closes-the-year.
What DfE is identifying
Aims that were continuing or completed at the previous year's final return and are now reported as having been withdrawn on or before 31 July of that year.
Based on FRM27 Summary.
Does appearing here mean something is wrong?
It means one of two records is wrong, and it is not always the one you would expect. Either the learner did leave last year and the withdrawal was recorded late, or the backdated date is itself an error and the learner was genuinely still in learning. Both happen, and they lead to opposite corrections, so establishing which before doing anything is the whole task.
Based on exception-is-not-error.
Legitimate reasons for appearing
- The learner genuinely left before 31 July and the withdrawal was notified after the previous year's final return had closed, which is a timing problem rather than a false record.
- A break in learning was subsequently reclassified as a withdrawal, giving an end date inside the previous year.
- The backdated date is wrong: somebody entered a leaving date to tidy a record and the learner was in fact still attending.
Based on break-in-learning-vs-withdrawal; completion-status-and-outcome.
Data or process problems that can cause it
- A withdrawal was known about before the year closed but was not entered until the new year had started.
- A leaving date was backdated to the last date of attendance without anybody considering that it crossed the funding year boundary.
- A record was cleaned up at the start of the new year and the end date entered was the date the learner was last seen rather than the date they formally left.
Based on withdrawal-timing-affects-performance; mis-generates-the-ilr.
What to check first
- Find out what the learner's status actually was on 31 July of the previous year, from attendance or engagement evidence rather than from the current record.
- Establish who changed the end date, when, and what prompted it.
Based on evidence-must-be-contemporaneous; change-evidence-matters.
Working through it
- Take the aim and find what the previous year's final R14 return said about it: which completion status, and what end date if any.
- Find what the current year's ILR now says: the completion status, the actual end date, and the withdrawal reason.
- Identify exactly which fields changed between the two returns, and by how much.
- Establish when the learner genuinely stopped attending, from register, engagement or employer evidence.
- Establish when that became known to the provider, and when it was entered into the student record system.
- Decide which record is correct: the one in last year's R14, or the backdated one. Do not assume the newer entry is the truer one.
- If the backdated date is right, the previous year's funding was overclaimed and DfE will contact you after R14. No in-year action is required and no EAS repayment should be submitted.
- If the backdated date is wrong, correct it in the source system so the learner's record reflects what actually happened, and regenerate the ILR.
- Record the reason for whichever change you make, because the change between returns is the thing anyone reviewing this will ask about.
Based on FRM27 Summary; FRM27 What you need to do; ilr-is-cumulative-in-year; correct-the-source-not-the-return.
ILR fields involved
- LearningDelivery.CompStatus
- LearningDelivery.LearnActEndDate
- LearningDelivery.WithdrawReason
- LearningDelivery.Outcome
Based on completion-status-and-outcome; planned-vs-actual-end-date.
Related ILR validation rules
- WithdrawReason_04
- CompStatus_03
Based on WithdrawReason_04; CompStatus_03.
Related PDSAT reports
- A-505
- A-506
Based on A-505; A-506.
Returns this relates to
- R14
Based on FRM27 Summary.
Funding implications
Where the backdated withdrawal is correct, funding earned in the previous year for the period after the learner actually left is an overclaim. DfE states it will recover this after the R14 return and will account for it through previous years' reconciliation processes rather than through the current year's final claims and reconciliation. Where the error spans more than one previous year, DfE warns the recovery could exceed the figure shown.
Based on FRM27 Summary; FRM27 What we will do; asf-is-earned-and-reconciled.
Audit and assurance implications
The change of a leaving date between two submitted returns is exactly the kind of unexplained change that draws a query. What settles it is a contemporaneous record of when the learner stopped, when that became known, and who authorised the change.
Based on change-evidence-matters; evidence-must-be-contemporaneous.
Achievement rate implications
When a withdrawal is recorded changes whether the aim counts in the achievement rate as well as what was earned. A withdrawal backdated into the previous year can therefore move the previous year's performance position as well as its funding.
Based on withdrawal-timing-affects-performance; qar-is-built-from-the-ilr.
Evidence to look for
- Registers or engagement records covering the period up to 31 July of the previous year.
- The internal notification of the withdrawal, and its date.
- The audit trail in the student record system showing who changed the end date and when.
- For an apprenticeship, the employer's confirmation of when the apprentice stopped, and any break in learning agreement.
Based on evidence-must-be-contemporaneous; break-in-learning-vs-withdrawal.
If the data is wrong
- Where the backdated end date is the error, correct it in the source system so the learner's record shows what actually happened, and regenerate the ILR.
- Do not submit a repayment for FRM27 through the earnings adjustment statement. DfE states explicitly that this is no longer the route.
Based on correct-the-source-not-the-return; FRM27 What you need to do.
If the data is right
- Record when the learner actually left, when the provider found out, and why the withdrawal could not be recorded before the year closed.
- Expect DfE to contact you separately after the R14 return about recovery, and hold the evidence ready for that conversation rather than waiting to assemble it.
Based on FRM27 What you need to do; change-evidence-matters.
Stopping it recurring
- Close the gap between a learner stopping and the withdrawal being recorded, since that gap is what produces this report.
- Check continuing aims before the final return of the year, while the year is still open and a correction costs nothing.
- Treat a leaving date that falls in a closed funding year as a change needing authorisation rather than a routine edit.
Based on final-return-closes-the-year; withdrawal-timing-affects-performance.
Questions an MIS manager should ask
- For each of these learners, what did we say at R14 and what are we saying now?
- Who changed the end date, when, and what were they working from?
- How long is the gap between a learner stopping attending and us recording it, and is that gap getting shorter?
- Do we check continuing aims before the final return, or only after DfE asks?
Based on change-evidence-matters.
Questions a finance director should ask
- What is our best estimate of the previous year's funding at risk here, recognising DfE's warning that it could exceed the figure shown if the error spans more than one year?
- Have we made any provision for recovery, given DfE will contact us after R14 rather than settling it in-year?
- Is this a handful of cases or a pattern, and if it is a pattern, what is causing it?
Based on FRM27 Summary; FRM27 What we will do.
What a good answer sounds like
- A good answer says what the learner's status genuinely was on 31 July, what evidence establishes that, and which of the two records is therefore wrong.
- A good answer is comfortable concluding that last year's return was right and this year's backdated date is the error.
- A weak answer is that the record has been corrected, without saying what it was corrected to or why the new version is the true one.
Based on exception-is-not-error.
Related Academy learning
- withdrawals-and-breaks
- year-end-close
- reconciling-funding
- qar-explained
Based on withdrawal-timing-affects-performance.
Funding streams this report reviews
DfE also names advanced learner loans. The Academy has no section for that stream yet, so it is listed here as published rather than mapped onto something only approximately similar.
FRM27 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.