Select Committee on Education and Skills Memoranda

Memorandum from Mr John Healey MP, Parliamentary Under Secretary of State for Adult Skills, Department for Education and Skills (ILA 53)


  1.  The Department for Education and Skills welcomes the Committee's decision to hold an inquiry into the closure of the Individual Learning Account (ILA) programme; the future of our lifelong learning strategy; and the management, policy and plans for the successor programme. The timing of the inquiry is particularly helpful as it allows us to consider the Committee's views and findings as part of the development of the new programme to ensure it is as effective as possible in building on the innovative features and successes of ILAs, remedying weaknesses and attracting adults back into learning. I also welcome further the opportunity to present this Memorandum to the Committee in advance of the hearing on 26 February 2002.


  2.  The 1997 Labour manifesto committed the new Government to introduce ILAs:

    "We will invest public money for training in Individual Learning Accounts which individuals—for example women returning to the labour force—can then use to gain the skills they want. We will kick start the programme for up to a million people, using the £150[1] million of TEC money which could be better used and which would provide a contribution of £150, alongside individuals making small investments of their own. Employers will be encouraged to make voluntary contributions to these funds."

  3.  The overall aim was to widen participation in learning and to help overcome financial barriers to learning faced by individuals. The ILA programme was universal; everyone aged 19 or over (subject to some nationality and residency conditions) had a right to an ILA. In this way, ILAs were designed to make an important contribution to the Government's objective of developing in everyone a commitment to lifelong learning.


  4.  The original delivery model, piloted in a variety of forms through Training and Enterprise Councils (TECs), envisaged the concept of a real, as opposed to a virtual, account where individuals could bank and save their own money in addition to any other contributions from, for example, Government, employers and trade unions. Despite extensive discussions with financial institutions, there was little enthusiasm from the finance sector to take this model on a national basis as it involved the maintenance of high volumes of low value transactions. Also, extensive market research found that individuals were not attracted by the notion of savings accounts solely for learning.

  5.  It was decided, therefore, to keep the concept of the individual, universally available, account but based on discounts for learning. It was felt that a new delivery mechanism was necessary in order to achieve the sort of cultural change in attitudes to training that was desired. In order to be sufficiently attractive for individuals to contribute to their learning, the mechanism had to be empowering, giving control and freedom of choice. Equally, the level of discount had to be sufficient to incentivise individuals to manage, plan and invest in their own learning throughout their lives, whilst ensuring they retained a personal stake through individual contributions.

  6.  Under the universal national framework, some specific groups were targeted through marketing: women returners, younger workers with low skills or few qualifications, self-employed people and non-teaching school staff. ILAs were also a mechanism to encourage the development of wider choice and innovation in the delivery of training and to attract new providers, not just established providers known to TECs and the Further Education Funding Council. This in turn would support improvement in the training market as individuals and their funding would flow away from inefficient and ineffective providers and make room for new providers, particularly those operating in smaller niche markets and with new, non-traditional learners.

  7.  The programme was introduced with a target of one million account holders by March 2002. Since there was always a limit (1 million) on the number of £150 incentives, two other incentives were also introduced:

    —  A discount of 80%, announced in the 1999 Budget, on a specific list of basic IT and maths courses and

    —  A 20% discount on the cost of a wide range of eligible learning. Certain types of learning were, however, specifically excluded, for example, higher education courses, professional qualifications and also learning where the outcome is in pursuit of leisure.

  8.  Because the objective was to bring in new learners and providers, the programme was designed to be simple and flexible for the learner and provider with the minimum of bureaucracy. The programme was designed to open up the learning market and to place as few restrictions as possible on what people could choose to learn; placing real purchasing power and consumer choice in the hands of learners for the first time. A fundamental principle of the design was that individuals had to pay a contribution for their learning. This personal investment aspect of ILAs was not only intended to give learners greater control over their personal development but also to increase their personal stake so that they would make sensible and informed decisions about their choice of learning. ILAs were not, however, intended to be a guarantee of quality of learning or learning providers as such Government endorsement might give an unfair market advantage to registered ILA providers.


  9.  The delivery of the ILA programme was enabled through a partnership arrangement through which Capita Business Services Ltd (Capita) captures and processes data on individuals and learning providers and also manages telephone and web-based call centre facilities.

  10.  The Department was responsible for the policy framework and overall design of the ILA programme, including the eligibility conditions for individuals and the definition of eligible and ineligible learning for funding. Capita were responsible for translating the policy intentions set out in the contract into a robust and functional system and for the operation of the system and associated call centre facilities to deliver the ILA programme. Their interpretation of this policy was presented in the form of a Business Rules Handbook, which was agreed by both the Department and Capita.

  11.  The Department and Capita jointly review the services provided against the detail set out in the contract using formal quarterly and annual review mechanisms and by way of an annual customer satisfaction survey. Changes made to the service become part of the formal change control process.


  12.  Building on the remit set out in the Manifesto, there were extensive consultations in developing the ILA policy. The Department actively engaged learning providers and other key stakeholders and partners (for example, through the consultative document "ILAs Making Them Succeed" (July 1997); ILAs Development Guide (April 1998); and a Windsor consultation (24-25 June 1999)). Building on the Budget Statement in March 1999 and the development of the statutory framework through the Learning and Skills Act 2000, various seminars were also held with learning providers and other partners in 2000.

  13.  Capita delivered the ILA programme through a national framework in partnership with the Department. Capita was appointed as the ILA customer service provider following a full OJEC tendering exercise. A letter of intent was signed in April 2000 but Capita began working on an action plan in March 2000. The contract dated 2 June 2000, valued at around £55m, was based on the appropriate Government Standard Contract tailored to reflect ILA requirements and to provide value for money for the public purse.

  14.  The Standard Contract was further developed to reflect the requirements of the ILA service and the needs of a new public/private partnership approach to delivery. In particular, the contract specifies a series of service, performance and payment details. A multi-disciplinary team consisting of DfES policy, finance and procurement staff, external consultants and commercial lawyers conducted negotiations with Capita. Those negotiations, together with contract signing, were overseen by the ILA Project Board which included a range of policy officials and specialists (Finance, Internal Audit, Procurement). DfES Ministers were involved in key stages of the process and were kept informed of progress.

  15.  Individuals were able to apply to become account holders and providers could register with the ILA Centre (ILAC) from June 2000. The ILA national framework was launched and ILAs became fully operational in England from September 2000 under the Individual Learning Accounts Regulations (England). This enabled individuals to benefit from discounts on their learning and allowed providers to make bookings on the ILA system and claim incentives for eligible learning. Incentives were not payable against any part of the course fees paid for by a third party such as an employer.

  16.  In October 2000, a major change was made to the delivery model. When the 80% discount for a specific list of IT and basic maths courses (eg City and Guilds 4242 ICT basics; BTEC IT desktop skills; GCSE and Key Skills 2 Maths and the European Computer Driving Licence) was introduced there was no cap on the eligible course costs that could be claimed. Regrettably, some unscrupulous providers exploited this to charge inflated prices and so a cap of £200 of support for any individual account holder was introduced.

  17.  On 7 November 2000, following detailed policy discussions and contractual negotiations, the English contract with Capita was amended to include the Scottish Executive and the Northern Ireland Department for Education and Learning.

  18.  Policy differences between England and the devolved administrations are set out in the table below:
PolicyEngland ScotlandWales N. Ireland
Minimum Age1918 1818
Level of 80% capInitially unlimited and then £200 200£200Initially £400 and then £200
Part-time Higher Education includedNo YesYesYes
Capita ContractYesYes NoYes

  19.  By 2 May 2001, the commitment to reach one million Individual Learning Accounts (964,000 in England) had been met, a year early, and an average of 3,000 accounts were being opened each day. At that time, more than half the people who had opened an ILA since January 2001 had not been in learning in the last three years. ILAs were clearly achieving the aim to make learning more affordable and accessible and playing their part in encouraging people to take responsibility for their own learning and development. Expenditure on the programme had reached some £90m at this point and the majority of this was on payments to learning providers for the introductory £150 ILA incentive using recycled TEC resources.

  20.  Over the summer, the Department received growing volumes of complaints from individuals and Trading Standards Officers about mis-selling, aggressive marketing, poor learning, poor value for money and alleged fraud. By end July, some 3000 complaints had been received and by end August this had risen to 4300. In response, the Department took action against unscrupulous learning providers and a number of important changes were made to the system. These included:

    —  The formulation of a Compliance Steering Group;

    —  Requiring all ILA Providers to sign and return an ILA Learning Provider Agreement from 30 June 2001,

    —  Removing 700 Providers who did not sign the Learning Provider Agreement from the Register on 14 July 2001; (105 were subsequently reinstated after signing the agreement.)

    —  Issuing a learner leaflet entitled "Choosing Your Learning", in August 2001;

    —  A compliance letter sent to all learning providers on 15 August 2001;

    —  Stopping third parties automatically receiving supplies of blank application forms;

    —  Increasing DfES and Capita resources on the investigation of complaints and cases for potential abuse;

    —  A complete re-draft of the Learning Provider Guidance (overtaken by the closure of the scheme);

    —  Setting up a joint DfES and Capita Compliance Unit, operational from 24 September 2001;

    —  From 28 September 2001, the Department suspended the registration of new providers and required that all ILA applications had to be made via the ILA Centre. Non-personalised applications were no longer accepted.

  21.  By end September 2001, we had received 6053 complaints (0.25% of account holders). By end October 2001, complaints had reached nearly 8500. These complaints covered a range of issues, including the ending of the £150 incentive, but a significant proportion related to money being taken from individuals' ILA accounts without their knowledge and others concerned the operation of ILAs by learning providers which suggested possible abuse and mis-selling. In addition there were a number of allegations of potential fraud.

  22.  As set out in Annex 1, by September 2001, expenditure on the programme had reached some £180m and had doubled since May 2001 reflecting rapid programme expansion over the period, exceeding all expectations. This also raised further concerns about the way the programme had been promoted and sold particularly in the light of growing evidence that some companies were abusing the system offering low value, poor quality learning. When considered together, the sharp increase in the volume and nature of the complaints we had received forced us to explore what action could be taken to safeguard public expenditure and secure value for money.

  23.  On 24 October 2001, the Secretary of State announced the decision to suspend the scheme from 7 December. That decision was taken at an internal meeting in the Department on 18 October and announced on the 24th. Having made that decision, colleagues within Government and the devolved administrations were informed. Over 8500 registered providers and 2.6 million account holders were then informed individually in writing.

  24.  It was clear that the light-touch, non-bureaucratic nature of the programme designed to reach non-traditional learners was successful—1.4 million learning episodes were booked—but regrettably, this also enabled a minority of unscrupulous learning providers to act against the ethos of the programme. Other key design principles to reduce financial barriers to learning and encourage individuals to take responsibility for their learning were also in part successful—16% of ILA redeemers had no previous qualifications and 22% had not participated in any training/learning in the 12 months preceding ILA use.

  25.  On 25 October, the Secretary of State announced plans to develop an ILA-style successor programme building on the best of the original—one that attracts non-traditional learners, one that balances measures to protect the public purse, provides simplicity for the learner and avoids bureaucracy for providers.

  26.  On Wednesday 21 November an approach was made to the Department by an ILA learning provider alleging that a third party had offered to sell them a large number of ILA account numbers. The Department arranged for a member of its Special Investigations Unit (SIU) to visit and interview the learning provider the next day. At the interview the SIU official was presented with a computer disc that had been passed to the learning provider, allegedly as evidence of the authenticity of the offer to sell ILA account numbers. The disc contained full names, addresses and contact details as would have appeared on the ILA record, as well as ILA numbers.

  27.  Checks on the disc confirmed the data to be live ILA account numbers which had either not been used at all (and which were therefore still available for use to claim funding) or which in some cases had been used to make a claim in the previous few days. The SIU conclusions were presented to Ministers on Friday 23 November. In the light of the confirmed evidence that the disc contained ILA numbers which had been obtained from the ILA database and the allegations that very large numbers of such ILA account details were being offered for sale, Ministers concluded, in line with police advice, that immediate closure of the programme, two weeks earlier than planned, was the only way to protect public funds. The steps taken over the summer and the early autumn to tighten up the operation of the scheme had clearly not stopped the problems. The rules and the robustness of the scheme were simply not sufficiently strong to allow us to prevent the misuse, and at the margins, outright abuse and some fraud that clearly was creeping into the system.

  28.  The devolved administrations took similar action as a consequence:

    —  Northern Ireland shut down the ILA Centre's operations on 23 November 2001 and the programme in Northern Ireland was effectively closed from that date. The problems of aggressive mis-selling common to other parts of the UK were apparent. The Minister for Employment and Learning had previously announced a review of the ILA programme as it applied in Northern Ireland, and the intention to bring forward revised arrangements as soon as possible in 2002.

    —  The ILA scheme was closed in Scotland with effect from Thursday 20 December as a result of concerns about the risks both to learners and the public purse of continuing the programme.

    —  New applications for ILAs were suspended in Wales as of midnight Friday 21 December 2001. This decision was taken following growing concerns about the activities of some direct marketing companies and learning providers who had adopted dubious practices in order to encourage people to apply for ILAs.


  29.  Since November 2001, investigative work has been continuing. By the end of January 2001, the total complaints received had reached nearly 18,300, (0.7% of account holders). Of these, some 5,800 related to money being taken from individuals' ILA accounts without their knowledge. Other complaints of a serious nature include poor value for money, aggressive marketing techniques, individuals' contributions not being collected and unsolicited learning materials being sent to learners. All such complaints will be followed up. These complaints relate to some 670 providers out of the total of 8910 registered providers. In the case of 153 of these providers, funds have been withheld pending further investigation and follow-up. In total, there are 482 providers who have claims outstanding for learning advance booked as at 23 November and where further validation checking will be required. Details are at Annex 2.

  30.  The DfES Special Investigations Unit is dealing with serious complaints and allegations of fraud and abuse in respect of 97 learning providers. Of these, the police have concluded investigations in one case and are investigating a further 15 learning providers (nine police forces are involved: City of London, Metropolitan, Leicestershire, West Midlands, Cheshire, National Crime Squad, Kent, Kendal and Dorset). The Special Investigations Unit is discussing a further 54 learning providers with the police. Internal and police investigations are necessarily thorough and of course this takes time, particularly with such a high volume of cases. To date, 44 arrests have been made in relation to allegations of fraud with the operation of the ILA programme. Charges have been brought against 14 of these people, one of whom has already been convicted.

  31.  Work is underway to resolve a range of outstanding issues resulting from the closure of ILAs. These relate to the implementation of payment procedures to enable the validation and processing of legitimate claims from providers; follow up and investigation of learner complaints and action to pursue recovery from providers for monies wrongly paid. The Department is allocating significant resources to help ensure that these matters are dealt with as swiftly as possible.

  32.  The majority (91%) of claims, with a value of £3.5 million, up to and including 21 November were paid to around 1400 providers before Christmas. Claims worth £11.3 million (representing 76% of the value of the payfile) were withheld from 136 providers, subject to further validation checks. Payments for eligible claims for learning booked and confirmed with the ILA Centre up to 23 November were made on 25 January. Again the majority of claims (94 %) relating to 1241 providers, with a value of £2.2 million were paid. Claims worth £2.4 million (representing 52 % of the value of the payfile) were withheld from 84 providers, subject to further validation checks. On 31 January officials wrote to all learning providers explaining the arrangements for payment of validated, eligible advance bookings of learning on the ILA Centre system up to 23 November. The latest date for confirmation of booked learning is 22 May 2002.

  33.  The Department set aside a budget of £202.1 million over the 2 years 2000—01 and 2001—02. This was based on achieving 1 million ILAs by April 2002. Spend up to 31 January 2002 has been £268.8 million following the high level of take up of ILAs. The final overspend, which will not be known until later in 2002—03, will depend upon a number of factors, in particular: the full extent of claims outstanding for learning booked at 23 November; the extent to which claims will be validated after investigation and analysis by officials and the amount of money recouped from providers who have filed invalid claims for payment. The final overspend will be met from within the Department's existing resources and resources have been identified for the successor programme.


  34.  An extended Departmental research brief providing updated information on how ILA holders view and use their ILAs was published on 21 December. The research followed on from a previous study in spring 2001 ("Evaluation of ILAs—England", published September 2001). It was conducted by York Consulting and involved a telephone survey of 659 Individual Learning Account (ILA) holders, including those who had been contacted as part of the earlier survey and more recent ILA holders. The research showed that:

    —  91% of ILA learning met or exceeded expectations[2].

    —  85% of ILA redeemers said the ILA had increased the training/learning options open to them[3].

    —  More than half ILA redeemers (51%) said they had little (27%) or no (24%) prior knowledge of the subject(s) they were studying with ILA support[4].

    —  22% had not participated in any training/learning in 12 months preceding ILA use[5].

    —  16% of ILA redeemers had no previous qualifications[6].

    —  54% of redeemers said their ILA made them more interested in learning[7].

    —  ILAs continued to attract more women than men (66% of recent redeemers were female compared to 59% of redeemers in the spring 2001 survey)[8].

    —  In common with the previous survey the majority of recent redeemers (82%) possessed some form of qualification prior to opening their ILA[9].

    —  Over a half of recent redeemers (56%) were employed—this is lower than in the previous survey (69%)[10]

    —  It estimated that over half (54%) of recent redeemers would have been able to pay for their most recent ILA supported course without their ILA. This suggests a higher level of "deadweight" to that of the earlier study, where it is suggested that 44% of redeemers could have paid for their course without an ILA[11].


  35.  We are determined to get to the bottom of what has gone wrong and our investigations have already identified a number of lessons which we need to draw on in designing and managing a successor programme. We will also ensure the lessons are shared more widely across the DfES and other Government Departments. There are still a number of strands of this work under way, however, and we will be updating this assessment as further analysis becomes available. In particular, we will shortly have a report on system security from Cap Gemini Ernst & Young and we will make available the main findings from this review in an updated "lessons to learn" in our response to the Select Committee's report.

  36.  The conclusions we have drawn so far can be summarised as follows:

    —  In terms of policy design, we need to build in stronger quality assurance mechanisms so that we minimise the chance of unscrupulous providers benefiting from the programme. This is a strong message that has come through from providers themselves. In designing a new programme, however, we will need to balance the need for stronger quality assurance with the need to preserve as much as possible of the simple non-bureaucratic processes which have also been a key to engaging new learners and learning providers;

    —  A related issue is that we need to develop better intelligence about unscrupulous providers and ensure that this is shared amongst different funding and contracting agencies. We plan further analysis of the companies where we are taking forward formal investigations to identify any links with other companies previously involved with fraud and abuse;

    —  There are important lessons about the process of risk identification and management. The ILA programme was managed with a risk log but it is clear with hindsight that this focussed too heavily on the risk of failing to meet programme targets. The Department should have specified a full business model for the ILA programme and subjected this to tests of how abuse could have occurred. This would have allowed us to identify other risks and design better monitoring systems to pick up early warning indicators. We will build this approach into the successor programme;

    —  There are also lessons about the management of a public/private partnership of this kind. We will build in stronger and clearer contract management arrangements into the successor programme, based on the risk analysis set out above as well as on performance and financial information;

    —  There are also important lessons about security when running open, non-bureaucratic programmes. It is clear from our experience with the ILA scheme that a balance must be struck between openness and security. We and Capita agree that any future ILA programme will require stronger security measures across the entire operation to guard against those who are intent on mis-using the programme. There will be a need for a tighter security architecture across the successor programme and more rigorous monitoring and management of the security arrangements.


  37.  It is too soon to be clear on detail or give a firm date for the introduction of the new scheme announced by the Secretary of State in October. We are committed to consultation with ILA providers and learners; drawing lessons from the ILA programme; and to remedy shortcomings in the programme. The DfES is also working closely with the colleagues in the devolved administrations to develop future plans. We are determined to review thoroughly all aspects of the ILA scheme before we decide on the details of the successor programme. We will, therefore, actively involve providers, learners and other stakeholders in the development work for a successor programme.

  38.  We began a consultation exercise in January. We are consulting all providers registered at the ILA centre, 1000 ILA account holders and other stakeholders (A list of organisations involved is at Annex 3) to ask them for their views on the principles behind the ILA programme and the strengths and weaknesses of its method of operation and control systems, including the registration of providers and learners. We are also inviting views on the form a replacement ILA-style scheme might take, views on the use of the ILA brand name and possible changes to the programme (for example the addition of quality assurance, the provision of additional advice and guidance to learners, and making some of the payment dependent on the completion of learning).

  39.  The final date for the completion of questionnaires and interviews is 28 February. In March the Department is holding 8 seminars to validate the findings of the consultation and to collect further views. Six of the seminars will be for providers, one for the TUC and one for the Association of Colleges.

  40.  Key issues emerging from the consultations to date include:

    —  Learning provider quality assurance arrangements: we are discussing with the LSC, and, through the consultation exercise, others, how we can use existing arrangements to help ensure that the provider base is quality assured;

    —  Targeting certain learner groups: the universal offer in ILA was very popular but led to some deadweight. We are considering whether to target the successor scheme to give us better value for money;

    —  Targeting certain learning: ICT learning was very popular in ILA, and it may make sense to consider targeting the successor scheme in a way that supports other Government policies, such as helping to close the digital divide.

  41.  In addition to work on the successor programme, we are currently considering financial support arrangements for adult learners (outside higher education), and are developing pilot arrangements, as announced in the pre-Budget report, that will test how free tuition together with employer compensation for time taken off by employees for learning can act as an incentive to learning. The Policy and Innovation Unit (PIU) published its initial report in December 2001, "In demand—Adult Skills in the 21st Century". The PIU is currently consulting widely within Government and beyond on the how best to take forward the workforce development strategy. These developments underline the Government's commitment to lifelong learning and to developing arrangements that break down the barriers to learning.

Mr John Healey MP

Parliamentary Under Secretary of State for Adult Skills

Department for Education and Skills

22 February 2002

Annex 1

MonthAccounts ComplaintsComplaints PercentageNo of Expenditure
openedreceived (in Receivedcomplaints Learning(Cumulative)[12]
(cumulative)Month) (cumulative)(cumulative) Providers
Sep 2000109,56452,241 5,949,672
Oct 2000214,880360 3650.162,939 12,231,396
Nov 2000292,641379 7440.253,500 33,068,858
Dec 2000347,175168 9300.263,876 40,136,718
Jan 2001446,724136 1,0660.234,322 45,729,618
Feb 2001556,928254 1,3200.234,781 54,107,629
Mar 2001661,558172 1,4920.225,383 65,695,333
Apr 2001781,572256 1,7480.225,785 76,691,231
May 2001988,539271 2,0190.206,321 90,169,229
Jun 20011,276,275346 2,3650.186,935 104,711,045
Jul 20011,578,014731 3,0960.197,449 127,851,914
Aug 20011,941,4681,208 4,3040.228,053 152,815,448
Sep 20012,386,2381,749 6,0530.258,471 180,015,080
Oct 20012,529,6092,395 8,4480.338,850 226,841,152
Nov 20012,620,6457,480 15,9280.618,910 260,888,560
Dec 20012,620,6451,335 [13]17,263 0.668,910264,974,254
Jan 20022,620,6451,015 [14]18,278 0.708,910268,835,094

Annex 2

Funds Withheld to DateEstimated Claims outstanding
No of
No of registered
registered providers£
Provider Categoryproviders £
Learning providers under police investigation 7£327,1887 £73,040
Providers where DfES is in discussions with police about investigation 30£3,319,94039 £1,065,460
DfES follow-up and investigation116 £11,029,070436 £7,035,490
Totals153£14,676,198 482£8,173,990

Annex 3


  Association of Colleges

  Association of Learning Providers

  Basic Skills Agency (BSA)

  British Chambers of Commerce

  British Computer Society

  BT Group

  Campaign for Learning


  Chartered Institute of Personnel and Development


  Engineering Employers Federation

  Equal Opportunities Commission

  Federation of Small Businesses

  Guidance Council


  Institute of Directors

  Institute of Management

  Investors in People UK

  Learning and Skills Council

  Learning and Skills Development Agency

  Local Government Association

  Ministry of Defence


  NHS Executive


  NTO—National Council

  Qualifications and Curriculum Authority

  Small Firms Enterprise Development Initiative




  Workers' Educational Association

1   This was a UK figure and the English share was £127.5 million. Back

2   Owens, Jane: York Consulting Evaluation of Individual Learning Accounts Early Views of Customers and Providers (England) Department for Education and Skills (DfES); interim report, supplemental tables; not published. Back

3   Owens, Jane: York Consulting Ltd Evaluation of Individual Learning Accounts Early Views of Customers and Providers: England Department for Education and Skills (DfES) Research Report 294: 9 September 2001. Back

4   Ibid. Back

5   Ibid. Back

6   Ibid. Back

7   DfES Research Brief No: RBX 01-02 "Individual Learning Accounts-Follow Up study"; January 2002. Back

8   As footnote 3 and 7. Back

9   As footnote 7. Back

10   As footnote 3 and 7. Back

11   As footnote 3 and 7. Back

12   Expenditure refers to total ILA programme payments - the majority represents payments to learning providers but also included are Capita contract payments, development pilots and other related programme costs. Back

13   Cum. complaints figure includes some 5900 logged complaints received by telephone and in writing from individuals who state money has been taken from their account without their knowledge or consent. The Department is presently scrutinising the log to remove any duplication in complaints recording. Back

14   As above. Back

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