Flexibility permitting EPA prior to Functional Skills Qualification Achievement | Pearson qualifications

Flexibility permitting EPA prior to Functional Skills Qualification Achievement

11 March 2021

Following a recent update from the Education and Skills Funding Agency (ESFA), a new temporary flexibility has been introduced.

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The full details of the update are covered in a document titled 'providing apprenticeships during the coronavirus (COVID-19) outbreak'. It outlines that apprentices at all levels, that are ready and waiting to take their Functional Skills Qualification assessments in English and maths, can undertake EPA and later return to complete their Functional Skills.

Read the full document

This flexibility is only available to apprentices where all possibilities to access FSQ assessment via face-to-face and remote assessment have been exhausted, and they have confirmed their intent to continue and complete their FSQ within three months of starting their EPA. Confirmation of this must also be evidenced in the learner file/evidence pack.

This resequencing of assessment can only occur if the following conditions are met:

  • Not be on a break in learning (an apprentice may return from a break in learning to take their end-point assessment)
  • Meet all other gateway criteria to progress to their EPA as specified in the apprenticeship standard (except meeting the English and math requirements)
  • Have been confirmed by the training provider and their employer as ready for both their EPA, and to take a functional skills qualification assessment
  • Start their EPA on or before 31 May 2021

Apprentices will still only complete their apprenticeship once they have passed their EPA and achieved their FSQ in English and/or math as required. After these achievements have been confirmed, Pearson, as the EPAO will request a completion certificate. This means that training providers will be expected to provide prompt confirmation of the apprentice’s FSQ results to EPA organisations once these have been awarded, to allow certification to be issued.

Next Steps

If you have an apprentice whereby this flexibility applies, you will need continue uploading gateway evidence into ACE360. In the Functional Skills components, upload a screen shot of the apprentice's Functional Skills test booking, titled Exemption. This will allow you to confirm gateway readiness and change the status of the apprentice to gateway approved.


Whist the apprentice can undertake their EPA using this flexibility, their overall apprenticeship certificate will not be claimed until confirmation of Functional Skills achievement has been provided.

Teacher Assessed Grades

Only where apprentices are unable to access a Functional Skills test through face to face, online or remote routes, can a request be made for Teacher Assessed Grades. Further information will be shared in due course, however additional information can be found on the Functional Skills FAQ webpage.

Suspension of Level 2 attempt rule

For level 2 (intermediate) apprenticeships, apprentices must achieve a level 1 in both English and math functional skills qualifications (FSQ) to complete their apprenticeship. Intermediate apprentices are also usually required to study towards and attempt the functional skills assessments at level 2. However, apprentices who are due to take their EPA on or before 31 March 2021 do not have to attempt the level 2 functional skills English and math assessment and can move through to gateway to sit their EPA.

If you have any questions or queries, please feel free to email epadelivery@pearson.com.


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