Proportion of planned employment, enrichment and pastoral (EEP) hours is 50% or more of total planned hours
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
In most cases, young people should be enrolled either in learning that leads to:
- an external certificate offered by a regulated awarding organisation and approved on the DfE list of qualifications approved for funding 14 to 19
- a substantial work placement to prepare them for progression to an apprenticeship or other employment
- a T Level
We have excluded students who have self-declared any learning difficulties and disabilities (LDD) or health problems or have been reported as requiring additional support.
Funding streams reviewed
- 16 to 19 study programmes
What you need to do
You must ensure that you have correctly recorded planned learning hours for any qualifications being delivered and recorded non-qualification delivery as EEP.
For non-qualification activity to be eligible for funding, you must be able to evidence that you have incurred a cost in delivering the activity that is proportionate to the amount of funding being recorded for this activity, and be able to demonstrate that it improves either progression to further levels of study or entry into employment.
What we will do
We may ask to review evidence of cost and need in-year to ensure that data is accurate, and value can be demonstrated. Your risk of audit will increase where EEP exceeds 50% of study programme hours.
Changes from previous funding year
None
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 16 to 19 students where half or more of their planned hours are employment, enrichment and pastoral hours rather than qualification hours. It does not say that enrichment is wrong. It says that when it becomes the larger part of a funded programme, DfE wants to see what it costs and what it achieves.
Based on FRM69 Summary; FRM69 What we will do.
Working knowledge
The comparison is the planned employability, enrichment and pastoral hours figure against total planned hours. DfE's expectation, stated in the summary, is that in most cases a young person is enrolled in learning leading to a regulated qualification approved for funding 14 to 19, a substantial work placement preparing them for progression to an apprenticeship or other employment, or a T Level. One point is easy to miss and changes how you read the list: DfE states it has already excluded students who have self-declared learning difficulties, disabilities or health problems, or who have been reported as requiring additional support. So the usual explanation for a high enrichment proportion has been taken out before the report was produced.
Based on FRM69 Summary.
Technical detail
DfE's instruction is to make sure planned learning hours are correctly recorded for any qualifications being delivered, and that non-qualification delivery is recorded as employability, enrichment and pastoral hours. A high proportion therefore has two possible readings: the split is right and the programme really is mostly non-qualification, or qualification hours have been under-recorded or left in the wrong field. DfE sets a separate eligibility test for the non-qualification part: evidence of a cost incurred that is proportionate to the funding recorded against it, and a demonstration that it improves either progression to further levels of study or entry into employment. It states plainly that audit risk increases where this exceeds half of study programme hours.
Based on FRM69 What you need to do; FRM69 What we will do.
Why this report exists
Planned hours decide the funding band without distinguishing what the hours are. DfE separates qualification from non-qualification hours so it can see where funded time is going, and this report is the point at which that balance becomes a question.
Based on planned-hours-drive-the-band; FRM69 Summary.
What DfE is identifying
16 to 19 study programmes where planned employability, enrichment and pastoral hours are half or more of total planned hours, after excluding students with declared learning difficulties, disabilities, health problems or reported additional support needs.
Based on FRM69 Summary.
Does appearing here mean something is wrong?
No. DfE does not call this an error and does not ask you to change it. It tells you what it will do, which is to ask for evidence of cost and need, and it tells you what follows, which is a higher risk of audit. A programme can be correct, well designed and still appear here, but it will need to be explainable.
Based on FRM69 What we will do; exception-is-not-error.
Legitimate reasons for appearing
- The programme is genuinely built around a substantial work placement or other non-qualification activity that DfE's own summary recognises as a valid shape.
- The student is part way through a programme where the qualification element is concentrated in a later year.
- The qualification hours are correct and the enrichment hours are correct, and the balance simply reflects the curriculum offer for that cohort.
Based on FRM69 Summary.
Data or process problems that can cause it
- Qualification delivery recorded in the employability, enrichment and pastoral field because it was easier than splitting the timetable.
- Planned learning hours under-recorded because only part of the qualification delivery was counted.
- A programme template applied to a cohort whose actual qualification hours are higher than the template assumes.
- Non-qualification hours built from an intended enrichment offer rather than the one timetabled.
Based on FRM69 What you need to do; mis-generates-the-ilr.
What to check first
- Look at what the enrichment hours actually cover, and confirm none of it is qualification delivery sitting in the wrong field.
- Confirm the planned learning hours capture all the qualification delivery for the year, not part of it.
Based on FRM69 What you need to do.
Working through it
- Take the planned learning hours and the planned employability, enrichment and pastoral hours as recorded, and the timetable behind each.
- Check the split is real: identify which timetabled activity sits in which field, and whether any of it is in the wrong one.
- If the split is right, establish what the non-qualification activity is and what it is intended to achieve for these students.
- Work out what that activity cost to deliver, and whether that cost is proportionate to the funding recorded against it, because this is the test DfE names.
- Establish how progression or entry into employment is improved by it, and how that is evidenced rather than asserted.
- Remember these students are outside the excluded group, so an explanation resting on additional support needs does not apply to this list and will not answer the question.
- Decide whether this is a recording problem, a curriculum design question, or a well founded programme that needs its evidence assembled.
Based on FRM69 What you need to do; FRM69 Summary.
ILR fields involved
- Learner.PlanEEPHours
- Learner.PlanLearnHours
- LearnerFAM.LearnFAMType
- LearnerFAM.LearnFAMCode
- LearningDelivery.LearnAimRef
- LearningDelivery.FundModel
Based on FRM69 What you need to do; LearnFAMType_16.
Related ILR validation rules
- PlanEEPHours_01
- PlanLearnHours_03
Based on PlanEEPHours_01; PlanLearnHours_03.
Related PDSAT reports
- Y-218
- Y-204
Based on Y-218; Y-204.
Returns this relates to
- R04
- R14
Based on r04-is-the-census-for-16-19; final-return-closes-the-year.
Funding implications
The total hours set the band, so moving hours between the two fields does not by itself change what is earned. What is at stake is whether the non-qualification part is eligible at all, which DfE ties to evidenced cost and demonstrable value rather than to the hours figure.
Based on planned-hours-drive-the-band; FRM69 What you need to do.
Audit and assurance implications
DfE states directly that risk of audit increases where this exceeds half of study programme hours, and that it may ask to review evidence of cost and need in-year. Assembling that evidence when the report appears is a great deal easier than assembling it when an auditor asks, and an audit sample is not confined to the records that prompted it.
Based on FRM69 What we will do; assurance-sample-is-extrapolated.
Evidence to look for
- The timetable for the enrichment and pastoral activity, showing what is delivered and when.
- The cost of delivering that activity, at a level that can be set against the funding recorded for it.
- The stated purpose of the activity and the progression or employment outcomes it is intended to improve.
- The qualification timetable, to confirm the learning hours figure is complete.
Based on FRM69 What you need to do; evidence-must-be-contemporaneous.
If the data is wrong
- Where qualification delivery has been recorded as enrichment, move it to planned learning hours as DfE instructs, and correct it in the system that owns the timetable.
- Where learning hours were under-recorded, correct the figure at source, regenerate and resubmit rather than editing the return.
- Where a template produced the split, correct the template so the cohort does not reappear next collection.
Based on FRM69 What you need to do; correct-the-source-not-the-return.
If the data is right
- Assemble the cost evidence and the progression case now, while the delivery is current and the people who designed it are still there.
- Record why the programme has this shape for these students, so the answer is the same whoever is asked.
Based on evidence-must-be-contemporaneous; change-evidence-matters.
Stopping it recurring
- Split qualification and non-qualification hours when the programme is designed, rather than allocating a total afterwards.
- Where a curriculum area intends a high enrichment proportion, build the cost and progression evidence into the programme approval rather than treating it as an audit task.
Based on mis-generates-the-ilr; FRM69 What you need to do.
Questions an MIS manager should ask
- Is any of what we have recorded as enrichment actually qualification delivery?
- Which courses does this affect, and is the pattern by course rather than by student?
- Do we know these students are outside the group DfE excluded, and have we stopped explaining them as support cases?
Based on FRM69 Summary.
Questions a finance director should ask
- What did the non-qualification activity cost us, and is that proportionate to the funding recorded against it?
- If we were audited on this tomorrow, what would we produce, and how long would it take to produce it?
- How much of our 16 to 19 funding sits on programmes with this shape?
Based on FRM69 What you need to do; pdsat-is-what-auditors-run.
What a good answer sounds like
- A good answer shows the timetable, the cost and the intended progression outcome, and says which students are affected and why the shape is deliberate.
- A weak answer is that the enrichment is good for the students, with no cost attached to it and no progression outcome named.
Based on FRM69 What you need to do.
Related Academy learning
- planned-hours-explained
- sixteen-nineteen-mechanics
- audit-readiness
Based on planned-hours-drive-the-band.
Funding streams this report reviews
FRM69 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.