Subcontracting Policy in Relation to Education and Skills Funding Agency (ESFA) Funded Programmes
Compass Skills Training Limited (‘Compass’) only uses a subcontractor to complement its own delivery where a subcontracting arrangement will enhance the teaching and learning for apprentices, e.g. by partnering with an employer or a specialist provider.
In accordance with ESFA rules, as the Lead Training Provider, Compass will undertake a substantive portion of the delivery of any apprenticeship where a subcontracting agreement is in place.
Rationale for Subcontracting
The main reason that Compass subcontracts higher and degree apprenticeship provision is to enhance the scope, reach and quality of our apprenticeship offer. This could include one or more of the following:
- A subcontractor is able to provide access to specialist staff or other resources that would otherwise not be available
- As a result of a collaborative partnership arrangement in which Compass is the Lead Provider
In all subcontracting agreements Compass retains oversight of the whole apprenticeship.
Subcontracting is agreed with employers prior to the commencement of the apprenticeship delivery and is clearly articulated in the Apprenticeship Training Services Agreement and the Commitment Statement.
Selection, approval and monitoring of subcontractors
Compass will only use delivery subcontractors who satisfy one of the following criteria:
- They are on the published Register of Apprenticeship Training Providers and have applied by the main provider route.
- They are the apprentice’s employer, and are on the published Register of Training Providers, having applied through the employer provider or supporting provider application route.
- Are a supporting provider who are not on the Register of Apprenticeship Training Providers, but will deliver less than £100,000 of training
Quality Assurance (QA) of delivery
Compass retains responsibility for all the actions of its delivery subcontractors that are connected to, or arise out of, all the apprenticeship training and on-programme assessment that is subcontracted to them.
Compass is committed to delivering high quality teaching and learning for apprentices and employers across its provision and will work with its subcontractors to review progress and manage the quality of external provision.
Compass will take a risk-based approach to subcontractor management to ensure that appropriate levels of contact monitoring and quality assurance (QA) are maintained.
Through this process Compass will collect, and risk assess, information about a proposed partner or subcontractor to ensure:
- The overall rationale for a proposed subcontract fits with Compass policies and strategy.
- The subcontractor’s capacity and track record in providing high quality provision.
- Appropriate legal and financial due diligence checks.
- That there are effective monitoring and performance review procedures to oversee the subcontract in line with ESFA rules and requirements.
- There are monitoring triggers and processes to intervene and terminate subcontracts as necessary.
In addition, the following processes will be used to monitor the quality of ESFA funded subcontracted provision and actively improve quality on an on-going basis:
- An initial visit to confirm approval of appointment as a subcontractor
- Regular contract review meetings between Compass and the subcontractor
- Regular planned and unplanned observation visits to check on the quality of teaching, learning, assessment and progress.
All subcontractors must agree to this schedule of meetings and QA visits prior to being awarded contracts.
Where contract reviews or QA visits highlight areas of concern the subcontractor will draw up an action plan to address the areas of concern, which must be agreed by Compass. Additional meetings and QA visits will be scheduled as required until the issues have been resolved. If an issue cannot be resolved within eight weeks of the issue being identified the Compass reserves the right to reallocate apprentices to a new provider.
Compass also considers feedback from apprentices in its quality assurance of a subcontractor.
Subcontractors must have the following policies and procedures in place which are to be maintained, reviewed and updated regularly:
- Staff Recruitment and Development
- Data Protection (GDPR compliant)
- Health & Safety
- Equality & Diversity
- Safeguarding & Prevent
Employer’s (compulsory) Liability Insurance = £10,000,000 any one occurrence/number of occurrences.
Public Liability Insurance Cover = £5,000,000 any one occurrence/number of occurrences.
The fees charged will be agreed on a case by case basis depending on the extent of services provided. This will include business factors such as:
- The level and type of professional training provided
- The level of on programme support provided to the apprentice and the employer
- The level of support provided to the subcontractor
- The commercial relationship between the parties
- The number of apprentices
Payment to subcontractors will be made within 30 days of the invoice being received, subject to all necessary paperwork and records having been submitted within the required timescale.
A checklist of key dates and deadlines for the paperwork to be received for inclusion in the return to the Education Skills Funding Agency will be provided. Payment details are also included in the contract Schedules which are issued to subcontractors at the start of the new contract year.
Declaration of use of subcontractors
In line with ESFA funding rules, Compass will submit a “Subcontractor Declaration” to the ESFA at least twice each year. The declaration summarises the value of any subcontracted provision paid for in the previous period.
The subcontracted provider is required to notify Compass immediately if there are any changes that may cause a risk to the contracted delivery. These include, but are not limited to:
- The possibility of the provider ceasing to trade
- Poor Ofsted inspection
- Poor ESFA audit
- Other significant changes that affect the ability of the subcontractor to deliver the required subcontracted provision
In these circumstances, Compass will conduct an immediate contract review and reserves the right to seek alternative provision of services to ensure continuity for learners.
Policy review and communication
Compass will review this policy annually. Any changes to the policy will be communicated to existing subcontractors at the contract management meetings. The policy will be discussed with new subcontractors prior to their engagement. An up-to-date copy of this policy will be posted on Compass’s website and paper copies will be made available upon request.