The sub-contractors policy is designed to ensure the efficient and effective management of our subcontracted provision.
ITEC NE’s aim is to build and sustain a working relationship with our sub-contractors whereby we share a common goal of providing all learners with high quality teaching, learning and assessment, while at same time maintaining the individuality and identity of each organisation in its pursuit of achieving outstanding provision.
This policy sets out how we go about achieving our aim.
ITEC NE is committed to:
- Promoting and developing a relationship with sub-contractors that is supportive, challenging, open, transparent and responsive.
- Having an ambitious vision to attain high standards of quality and performance.
- Improving teaching and learning through rigorous performance management and professional development.
- Evaluating the quality of provision through robust self-assessment.
- Listening to our learners and using the findings to promote and develop our capacity to improve.
- Promoting equality and diversity and ensure that all learners are safe.
- Ensuring the sustainability of our sub-contractors and supporting their growth strategies.
- Ensuring that the sub-contractor is not inadvertently funding extremism.
RATIONALE FOR SUB-CONTRACTING
ITEC NE engages with sub-contractors to better meet customer needs. Our main reasons include:
- Provide access to, or engagement with, a new range of customers
- Provide niche delivery where the cost of developing direct delivery would be inappropriate
- Support employers throughout the North East recruit and train
- Balance our delivery so that we support a wide cross section of learners, including the following:
- School and college leavers seeking employment with training (apprenticeship)
- Employed without occupational qualifications (direct apprenticeships)
- Long term unemployed aiming to return to employment (functional skills and employability training.
In line with the requirements set out by the Skills Funding Agency ITEC NE is required to notify the Skills Funding Agency of their sub-contracting arrangements through the completion of a declaration form.
In addition ITEC NE is required to provide the Skills Funding Agency with a single signed declaration that the necessary due diligence has been carried out across all proposed sub-contractors.
MANAGEMENT OF SUB- CONTRACTORS
To ensure the efficient and effective management of our subcontracted provision ITEC NE will implement the following arrangements:
Selection and approval of sub-contractors (Due Diligence)
All potential sub-contractors must meet the following principles:
- Complement the strategic objectives of ITEC NE
- Can demonstrate community benefit and/or widening participation
- Are aligned to the key sectors that ITEC NE have prioritised
- Have potential to achieve good or outstanding provision
- Are committed to achieving a high success rate
- Are willing to engage in mutually supportive relationship building
- Have clear policies in place to safeguard their learners, including the risks of radicalisation
To become an approved sub-contractor with ITEC NE the organisation must provide a range of information to enable ITEC NE’s Senior Management Team carry out a due diligence exercise. Appendix A outlines the information that must be provided before ITEC NE will enter into any contractual arrangements.
As part of our contract management arrangements ITEC NE will:
- Enter into an annual signed contract with each sub-contractor, signed by both parties setting the terms and conditions of engagement.
- Agree contract value, including a breakdown of programmes to be delivered within an estimated timescale.
- Review quarterly against plan and modify contract if necessary.
- Review performance at end of year and agree contract targets for the following year.
All sub-contractors must maintain a personal/training file for each learner. The file must include:
- A signed agreement between training provider and learner.
- Evidence of a contract between employer and learner (if appropriate) showing that the learner is undertaking an apprenticeship with the employer in a specific occupation.
- Evidence of teaching, learning and assessment.
- Individual Learning Plan, that shows the outcome of initial assessment, clearly defined outcomes and regular reviews.
ITEC NE will:
- Carry out regular audits of learner’s personal/training file to ensure contract compliance and enable the sub-contractor to demonstrate the training and assessment they have undertaken. Two document audits will be completed in each contract year; the audit will involve sampling a percentage of on programme learners and those that have completed training and early leavers.
- Sample interim and completed portfolios (please note that although it is not the responsibility of ITEC NE to undertake IV activity it is important that we see evidence in portfolios that are consistent with records in the learners training file).
A full 100% audit will only be undertaken if concerns have been identified either from the sample of other information e.g. high number of early leavers.
Observation of the learner journey
ITEC NE will carry out observation of the delivery of the learner journey. These observations will be carried out by a member of the quality team and may also involve joint observation with a member of staff from the sub-contracting organisation.
The person being observed will be given verbal feedback after the observation. A written report will be given to the trainer/assessor and the appropriate manager. It is envisaged that the manager will use the information to develop individual training plans and incorporate into the self assessment report and quality improvement plan.
The number and frequency of observations will be agreed with the sub-contractor and determined by risk banding of trainers/assessors.
Performance management and quality assurance
An essential part of the management of sub-contractors is ensuring that sub-contractors have in place arrangements to manage the performance and quality of their provision. ITEC will therefore monitor the leadership and management of sub-contractors to ensure that the organisations have the appropriate arrangements in place to effectively manage their provision.
ITEC will focus on monitoring:
- Outcome of learners
- Planning and preparation documentation
- Learner induction
- Individual learning plans
- Review of progress
- Assessment/learner feedback
- Observation of learning
- Internal verification
- Internal moderation
- Use of technology
- Review of quality improvement
ITEC NE will require each sub-contractor to produce an annual self-assessment report and maintain an up to date quality improvement plan. This information will be monitored as part of the agreed ongoing quality audit process.
Policies updated and implemented
All sub-contractors must have a range of policies in place to meet requirements of SFA and awarding bodies. Although these policies will be checked as part of the due diligence exercise ITEC NE will require sub-contractors to update policies and demonstrate the strategies in place to implement the policies.
Training and support
ITEC NE will provide training and support to all our sub-contractors. This is achieved by:
- Sharing information on good practice
- Jointly attending seminars and courses
- Developing joint initiatives
- Providing training in specific area, for example safeguarding.
- Sharing training resources
- Providing advice and guidance following observations in order to drive up the quality of teaching and learning.
Contingency plan in case of non-delivery
In compliance with Skills Funding Agency and other agency funding rules that apply, if a sub-contractor withdraws from the arrangement, or if a sub-contractor goes into liquidation or administration, ITEC NE undertakes to directly manage and deliver the remainder of the agreed provision already being delivered. This delivery will be either through the existing structure or by retaining tutor expertise and/or specialist equipment, whichever is more cost-effective. Any provision planned but not started will be cancelled and the project closed.
If ITEC NE needs to withdraw from a sub-contracting arrangement, sufficient notice will be provided to allow sub-contractors to complete delivery of immediate provision. ITEC NE will provide support to enable sub-contractors to identify other sources of funding if possible, or take appropriate action to complete the project, or close the project at the earliest opportunity, without prejudice to currently enrolled learners or staff.
Contracts will clearly state conditions for termination and recovery of SFA funding grants in case of non-delivery.
MANAGEMENT CHARGES AND PAYMENT ARRANGEMENTS
ITEC NE has a standard charge for the management of sub-contractors of 15% of funding drawn down from SFA. This is a fixed percentage and is incurred upon the sub-contractor to meet the administrative, quality audits and ongoing support costs associated with being a prime contractor.
However, charges may increase up to 20% if the level of support required is over and above our normal level of service, for example a new sub-contractor with no previous experience of delivering apprenticeships and/or accredited classroom courses could be charged at a higher level throughout their first year of sub-contracting with ITEC NE.
Payments are made to sub-contractors on or about the 15th of the month following a completed month of delivery, subject to the sub-contractor submitting an invoice for a payment level previously confirmed by ITEC NE.
POLICY REVIEW COMMUNICATION OF THE POLICY
ITEC NE reviews all of its policy annually in January; these changes are immediately communicated to the sub-contractor. However, no changes will be implemented throughout the contract which would impact on the sub-contractors capability to deliver the contractual targets.
ITEC NE’s policy, including any modifications, is communicated to the sub-contractor prior to them signing the annual sub-contractors agreement.
PROCESSES, PROCEDURES AND GUIDANCE
The management of sub-contractors is supported by processes, procedures and guidance to ensure the policy is effectively implemented throughout ITEC NE and all organisations that work in partnership with the company.
ROLES AND RESPONSIBILITIES
To ensure the policy is fully implemented it is essential roles and responsibilities are clearly defined for all staff with regard to management of sub-contractors. Outlined below are the roles and responsibilities for the Board of Directors and all personnel.
Board of Directors
- Ensure ITEC NE has developed and implemented the management of sub-contractors policy and strategy.
- Monitor the performance of sub-contractors.
- Overall responsibility for the development and implementation of the management of sub-contractors policy and strategy.
- Approve new applications from sub-contractors and agree annually the percentage of ITEC NE’s SFA contract to be allocated to sub-contractors.
- Monitor the performance and quality of sub-contractors provision.
- Update sub-contractors of developments introduced within the sector, including requirements set out by SFA and OFSTED.
- Evaluate application from new sub-contractors and carry out due diligence.
- Annually draw up and agree contracts with new and existing sub-contractors.
- Review sub-contractors performance against planned profile and modify allocation in response to existing performance and planned projections.
- Ensure sub-contractor are paid in accordance with the agreed contract.
- Risk assess the capability of the sub-contractor to deliver and manage the delivery of training.
- Implement an annual plan of observations, file audits and quality assurance reviews to ensure the sub-contractors are managing and delivering their training programmes in accordance with the requirements set by ITEC NE.
- Provide training and support to sub-contractors to enable them to efficiently and effectively deliver their education and training provision.
- Maintain records of meetings, observation and audits.
- Organise the completion of self-assessment reports by sub-contractors and monitor progress against their quality improvement plans.
- Carry out observations and file audits.
The policy will be updated and reviewed annually to ensure it is aligned to the mission, vision, values and strategic direction of ITEC NE.
All procedures and guidance notes will be reviewed every two years; however there will be ongoing modification of procedures to reflect changes and to promote good practice throughout the organisation.
This policy has been approved and signed by the Board of Directors. The signed copy is held internally at ITEC NE Head Office.
To become an approved sub-contractor with ITEC NE the organisation must provide the following of information to enable ITEC NE Senior Management Team carry out a due diligence exercise:
- Company overview including three year strategic plan
- Finance statement
- Appropriate Insurance
- Director/Senior Manager previous appointments
- Awarding body approvals
- Quality assurance policy and procedure
- Staffing structure – present and planned changes over next twelve months
- Staff CV and training plan for next twelve months
- Staff development policy
- Health and safety policy
- Equality and diversity policy
- Safeguarding policy
- Prevent and radicalisation policy
- Delivery models including scheme of work and lesson plans for each course/occupational area.
- Relevant documentation to complete individual learning plans, monthly action plans and reviews.
- Quality assurance arrangements including internal verification, observations strategy, capturing learners and employer opinion
- Complaints arrangements
- Previous self assessment report and action plan or SWOT analysis and key priorities for next twelve months
- Appeals procedure
- Key processes for delivery of training
- Other sub-contract arrangements
- Employer engagement, including sector and training requirements