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Skills Programmes Subcontracting Policy

INTRODUCTION 

The subcontractor’s policy is designed to ensure the efficient and effective management of our sub-contracted provision.

Triage’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 the 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.

COMMITMENT

Triage 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 ensuring 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

Triage 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:
  • Long term unemployed aiming to return to employment (functional skills and employability training).
  • Individuals who share protected characteristics and/or form part of disadvantaged groups
  • Those who live in more remote areas and require access to support

SUB-CONTRACTING ARRANGEMENTS

In line with the requirements set out by the Education and Skills Funding Agency and/or Tees Valley Combined Authority, Triage is required to notify the Education and Skills Funding Agency of their sub-contracting arrangements through the completion of a declaration form.

In addition, Triage is required to provide the Education and Skills Funding Agency and/or Tees Valley Combined Authority 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, Triage will implement the following arrangements:

  1. Selection and approval of sub-contractors (Due Diligence)
  2. All potential sub-contractors must meet the following principles:
  • Complement the strategic objectives of Triage 
  • Can demonstrate community benefit and/or widening participation
  • Are aligned to the key sectors that Triage 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

3. To become an approved sub-contractor with Triage, the organisation must provide a range of information to enable Triage’s Senior Management Team to carry out a due diligence exercise

CONTRACT MANAGEMENT

As part of our contract management arrangements, Triage 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 delivery plans and modify contract if necessary.
  • Review performance at end of year and agree contract targets for the following year where required.

DOCUMENT AUDIT

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 a learning aim.
  • Evidence of teaching, learning and assessment.
  • Individual Learning Plan, that shows the outcome of initial assessment, clearly defined outcomes and regular reviews.

Triage 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 Triage 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% funding assurance audit will be undertaken on all learner files  

OBSERVATION OF THE LEARNER JOURNEY

Triage 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. Triage 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. 

Triage 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     

The subcontractor is required to ensure that all personnel engaged in performing the Sub-Contract Services have the appropriate skills, training and qualifications to perform the tasks allocated to them as a minimum they must hold the following:

  • Teaching certificates
  • Vocational specialism at a level higher than that being taught
  • Level 2 Maths and English (or equivalent) 

Triage 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 the Education and Skills Funding Agency and/or Tees Valley Combined Authority and awarding bodies. Although these policies will be checked as part of the due diligence exercise, Triage will require sub-contractors to update policies and demonstrate the strategies in place to support this.

TRAINING AND SUPPORT

Triage 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 areas, for example, safeguarding.
  • Sharing training resources
  • Providing advice and guidance following observations in order to drive up the quality of teaching and learning.
  • Offering opportunities to attend events to recruit learners and access local partners and employers

CONTINGENCY PLAN IN CASE OF NON-DELIVERY

In compliance with the Education and Skills Funding Agency and/or Tees Valley Combined Authority funding rules that apply, if a sub-contractor withdraws from the arrangement, or if a sub-contractor goes into liquidation or administration, Triage undertakes to directly manage and deliver the remainder of the agreed provision already being delivered. This delivery will either be 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. Triage will:

  • Take reasonable steps to protect the interest of the learners in relation to their qualification
  • Inform affected learners / apprentices in a timely fashion
  • Make sure the learners/apprentices already registered for the qualification have been provided with relevant alternative options and information to allow them the opportunity to complete their qualification 
  • Support the learners/apprentices to identify alternative Training Provider in their local area to complete their qualification
  • If no alternative centres are available or suitable, or the learners do not wish to continue with their qualifications, Triage will ensure that all learners/apprentices are certificated for any units they have completed to date in accordance with the requirements of the Awarding Body specifications.
  • Inform any relevant funding authority

If Triage needs to withdraw from a sub-contracting arrangement, sufficient notice will be provided to allow sub-contractors to complete delivery of immediate provision. Triage 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 Skills Funding Agency and/or Tees Valley Combined Authority funding grants in case of non-delivery.

MANAGEMENT CHARGES AND PAYMENT ARRANGEMENTS

Triage has a standard charge for the management of sub-contractors of 18% of funding drawn down from Skills Funding Agency and/or Tees Valley Combined Authority. 

This is a fixed percentage and is incurred upon the sub-contractor meeting the administrative, quality audits and ongoing support costs associated with being a prime contractor.

Associated costs reflect those incurred in the commissioning, procurement and due diligence processes, contract management, quality assurance, provider development and administration activities undertaken by Triage. This approach derives a differentiated rate based on the size of the contract allocation to ensure costs are reasonable and proportionate to the delivery of subcontracted provision.

Specific activities and weightings are set out below 

  • Commissioning and Procurement (3%)
  • Contract Management and Quality Assurance (10%)
  • Contract Administration (5%)

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 Triage.

The cost claimed per individual qualification will be determined at the start of each academic year and outlined in the contract. To ensure this is reasonable and proportionate to the delivery of teaching and learning, the Education and Skills Funding Agency funding rates will be applied and/or an amount will be agreed with the Tees Valley Combined Authority for each qualification.  

Payments will be made to sub-contractors following a completed month of delivery, subject to the learner documentation meeting the required funding rules. Upon submission and approval of learner documents, partners will be provided with a Providers Funding Report (PFR) on a monthly basis and expected to submit an invoice which will be paid within 30 days.

Triage reserves the right to withhold payments and/or retrieve payments already made should a sub-contractor not be able to meet the requirements set out within the contract. This could include, but is not limited to, insufficient quality, accuracy or completeness of leaner documentation, significant underperformance against set profiles, failure to provide any records or other information as reasonably requested by Triage.

COMMUNICATION OF THE POLICY

No changes will be implemented throughout the contract which would impact on the sub-contractor’s capability to deliver the contractual targets.

Triage’s policy, including any modifications, is communicated to the sub-contractor prior to them signing the annual sub-contractor’s 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 Triage 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 Triage has developed and implemented the management of sub-contractors policy and strategy.
  • Monitor the performance of sub-contractors.
  • Operations Director
  • Overall responsibility for the development and implementation of the management of sub-contractor’s policy and strategy.
  • Approve new applications from sub-contractors and agree annually the percentage of Triage’s Education and Skills Funding Agency and/or Tees Valley Combined Authority contract to be allocated to sub-contractors.
  • Evaluate applications from new sub-contractors and carry out due diligence.
  • Annually draw up and agree contracts with new and existing sub-contractors.
  • Risk assess the capability of the sub-contractor to deliver and manage the delivery of training.
  • Head of Delivery
  • Monitor the performance and quality of sub-contractor’s provision.
  • Review sub-contractor’s performance against planned profile and modify allocation in response to existing performance and planned projections.
  • Ensure sub-contractors are paid in accordance with the agreed contract.
  • Update sub-contractors of developments introduced within the sector, including requirements set out by the Education and Skills Funding Agency and/or Tees Valley Combined Authority and OFSTED.
  • Allocate each subcontractor a dedicated Performance Manager who will conduct monthly Contract Review Meetings and provide operational support
  • Quality and Compliance Manager
  • 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 Triage.
  • 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.

MONITORING AND REVIEW

This policy is subject to an annual review cycle, to ensure it remains fit for purpose and to ensure it is aligned to the mission, vision, values and strategic direction of Triage.

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.