This policy outlines the approach The Skills Company will take in regards to subcontracting Skills Funding Agency (SFA), Education Funding Agency (EFA) funded provision and will also include ESF supply chain management as appropriate.
This policy compliments the strategic plan within Economic Solutions with particular drivers from the Greater Manchester Strategy, which aims to support the economic development of Greater Manchester, The North West and England. Delivery outside of Greater Manchester (GM) will be assessed against the subcontracting framework.
This policy sets out how and why The Skills Company will carry out any sub-contracting and outline the impact that should be delivered. Our aim is to build long term partnerships with providers who can complement and strengthen our skills offer and grow GM productivity.
To support this, we enter in to both fully subcontracted (provision subcontracting) and joint delivery arrangements. The rates given in this policy relate to our fully subcontracted (provision subcontracting) arrangements. Rates for joint delivery vary dependent upon the agreed mix of delivery.
The following policy applies to all provision that is subcontracted and replaces any previous versions, where applicable, and is effective from 1st August 2016. The policy will be reviewed at least annually and will be published on our website www.theskillsco.com/subcontracting
- To widen participation and respond quickly to employer and learner demand, meeting our customers’ needs
- To deliver a wide sector offer that responds to local and regional priorities
- To support and compliment directly delivered provision
- To maintain the delivery of niche provision and support local communities
- To support a partner provider to develop capacity/quality
- To support the unemployed back in to work with vocational training routes
- To support and complement government priorities
The Skills Company will only work with good quality providers and for Traineeship provisions the Subcontractor must have a Grade 1 or 2 Ofsted Inspection Grade.
In 16/17 we will continue to work with our approved sub-contractors who meet our due diligence and quality indicators. We will also publish a prospectus outlining which areas of delivery and priority groups we want to reach in this year. This will enable us to develop a register/framework of approved subcontractors and implement to effect new learning opportunities. We will invite providers to complete an Expression of Interest.
As part of the due diligence process the subcontractor will need to provide Economic Solutions with the following:
- Details of Partners/Directors, contact names and addresses and company registrations
- Latest audited accounts to support a financial viability health check
- Health and Safety/ Safeguarding Policies and practices
- Details of other SFA/EFA contracts and a references
- Equality and Diversity Policy
- Schemes of Learning for proposed programmes
- Observation grades for teaching and learning
- Details of premises and resources to support proposed training
- Details of accreditation
- CVs including professional qualifications and DBS checks of all staff
- Evidence that staff have undertaken Safeguarding Training
- Data Protection Policy
NB: this is not an exhaustive list – please refer to our Proposal documentation for full requirements.
The due diligence information provided will be assessed using a scoring matrix. Contracts will not be issued to subcontractors who fail the financial checks.
QUALITY ASSURANCE AND IMPROVEMENT
The Skills Company is committed to supporting all Subcontract partners to develop and deliver high quality provision through robust quality assurance and improvement processes. In addition, through the delivery of capacity building support, a comprehensive programme of quality and compliance activity is provided to ensure public funds are protected and used effectively to deliver high quality provision for learners and employers.
The Skills Company promotes a rigorous self-assessment model and will require evidence of self assessment in subcontractors that leads to operational and strategic improvement in provision. Support on self assessment and continuous improvement will also be provided through our capacity building programme.
Our Subcontracting Management Team undertakes regular Quality and Compliance Review meetings. As part of this activity they will review:
- Quality Assurance Policy and its implementation and effectiveness
- Verification of Assessment Practices and Standards (EQA Reports and IQ Plan)
- Classroom/Workplace Delivery Methodology and Effectiveness, to include: Observation Policy and Procedures, Observation of Teaching, Learning and Assessment Criteria, Samples of Graded Observation Reports, Learner and Stakeholder Views
- Compliance with contractual and funding requirements
- Administration of AGE Grant
Frequency of Quality Review meetings will be determined based on a risk assessment approach.
SUBCONTRACT FEES POLICY
The standard subcontract management fee is 15% of the SFA/EFA funding received against each learner as outlined in SFA good practice guidelines. This will apply to:
- Full subcontracting (Provision)
- Employer led subcontracting
- College partners
However, where a new Subcontractor needs more intensive support and management then a higher management may be negotiated as appropriate. This is to reflect the resources required to provide more intensive support to ensure quality standards are being met and any risk is being properly managed during any development process. At the end of the agreed period and once all quality thresholds are met the subcontractor will transfer to the applicable standard rate.
Rates for joint (mixed) and employer led delivery may vary dependent on the agreed mix of delivery.
In addition to the direct support, The Skills Company provides a broad range of management information and performance reports to support the effective and timely delivery to learners and to monitor performance against agreed targets for the subcontractor.
Management fees will be deducted at source and will have been deducted before allocation and maximum contract value are confirmed in contracts. All funding claims must comply with the current SFA/EFA Funding Rules/Guidance and the terms of the contract with Economic Solutions.
FINANCIAL HEALTH ASSESSMENT OF THE SUBCONTRACTOR & ROTO
The Skills Company undertakes a financial health assessment of all subcontractors. Provision subcontractors with proposed contract values in excess of £100,000 must be present on the Register of Training Organisations (ROTO) before a subcontract can be issued.
The Subcontracting Team will support the subcontractor to complete the process and where appropriate also support them to enter the Register of Training Organisations (ROTO).
The Skills Company will make payment to subcontractors 30 days following receipt of claim/invoice. Payment is subject to the correct evidence and data being provided to The Skills Company by the agreed monthly deadline. Adjustments may be made to specific payments where evidence of eligibility, participation or achievement cannot be validated by The Skills Company. Where funding claims cannot be substantiated, The Skills Company will adjust and reclaim any funds from the subcontractor and where required make and appropriate repayment to the SFA/EFA.
POLICY REVIEW AND PUBLICATION
This policy will be reviewed annually in July of each year, and any changes notified to subcontractors as part of either their regular contract review or through separate correspondence.
For further information please contact the subcontracting team