Our use of subcontractors in apprenticeships (2019/20 funding year)
A statement on the approach to subcontracting elements of the Apprenticeship offer at Solent
Background
Solent University is committed to delivering high quality apprenticeships that meet the needs of apprentices, employers, and the wider labour market. In most cases, all delivery of the apprenticeship will be carried out by the University, however in some limited instances, we will work with a third party who would support our delivery with the provision of selected services within the apprenticeship. This will only be in instances where the use of the third party would enhance the apprentice experience and it is agreed with the employer that the service can meet or exceed the academic standard required within the apprenticeship. At all times, Solent leads the employer relationship
Use of subcontractors
Our subcontract relationships will be in one of two forms:
- Subcontract for Functional Skills English and Maths delivery
- Subcontract to the employer for delivery of selected knowledge, skills or behaviours (at cost price to the employer)
Any subcontractor must pass a detailed due diligence process which includes but is not limited to: appraisal of Ofsted or applicable assurance reports for validation of quality, appraisal of trainer qualifications, business continuity plans and must be on the Education and Skills Funding Agency (ESFA) Register of Apprenticeship Training Providers. If a subcontractor is not on the register they will not be approved for partnership for Apprenticeship programmes.
In all instances, Solent retains clear and transparent accountability for the quality of training provision, maintains proper and appropriate controls to manage the apprentice experience, and seeks to ensure that value for money is achieved by efficient subcontractor management. These controls are validated by an annual subcontractor controls evaluation carried out by an independent assurance specialist.
In all instances Solent would provide quality assurance through close monitoring by the head of apprenticeships and officers of the University. The types of subcontract arrangement, quality assurance and costs of the models are explained in more detail below.
The written agreement (contract) with the employer for apprenticeship provision will always list the costs of the subcontract in line with the apprenticeship funding rules shown in Annex 1, below, so that all costs are transparent. A declaration is made by Solent to the ESFA twice a year declaring any subcontractors used.
Subcontract types at Solent
Functional Skills English and Maths delivery
Where an apprentice does not possess English and Maths transferable skills at level 2 or above, Solent will select a training provider with specialism for delivery of the English and Maths Functional Skill qualifications necessary for the apprentice to meet the requirements of the Apprenticeship standard. Where a specialist provider is unavailable Solent would deliver these aims.
Employer delivery of selected knowledge, skills or behaviours
Where it is in the apprentice’s best interests by way of enhancing the apprenticeship experience, we can approve the apprentice’s employer to deliver selected units from within our programme. This will only be in instances where the employer has sufficiently qualified persons and expertise to deliver at or above the level required to meet learning outcomes.
Services we provide to quality assure subcontracted provision
The head of apprenticeships has responsibility for assuring the quality of delivery of subcontracted provision and a regular programme of activity is agreed to monitor provision
This includes a regular and substantial programme of quality-assurance checks on the apprenticeship training and on-programme assessment provided by delivery subcontractors, including visits at short notice and face-to-face interviews with staff and apprentices to ensure apprentices exist and are eligible; and involves direct observation of initial guidance, assessment and delivery of training and/or on-programme assessment.
In the functional skills subcontract model, Solent retain all responsibility for resolving any issues and disputes between the employer and delivery subcontractor. In the employer subcontract model issues and disputes will be managed by the head of apprenticeships.
Subcontract funding
Functional Skills will be subcontracted out at the exact ESFA funding rate of £471 per functional skill with Solent absorbing the costs of quality assurance within our broad revenue streams.
Employer delivered knowledge, skills or behaviour will be funded at or below cost price to the employer using the guided learning hours defined within Solent’s scheme of work for the relevant unit at the hourly wage (including on costs) of the individual delivering to the apprentice. This value takes into account variations for methods of delivery and is to ensure the employer only receives funding of value at or below their costs of delivery aligned to the funding rules for eligible and ineligible costs. The training price funded by the ESFA will take this price and management costs of the subcontract into consideration.
Our contracts with subcontractors
A contract is put in place between Solent and each delivery subcontractor which specifies the following:
That the subcontractor must
- keep to the funding rules
- provide us with data so that our data returns to the ESFA accurately reflect delivery information
- Give the ESFA and any other person nominated by the ESFA access to their premises and to all documents related to their delivery of apprenticeships
- Give Solent sufficient evidence to allow
- Assessment of their performance against Ofsted’s common inspection framework or the requirements of the QAA quality code;
- incorporate the evidence the subcontractor provides into Solent’s self-assessment report; and
- guide the judgements and grades within Solent’s self-assessment report
- Always have suitably qualified staff available to provide apprenticeship training and/or on-programme assessment
- Co-operate with Solent to ensure that there is continuity of learning for apprentices if the subcontract ends for any reason
- Communicate in writing to Solent if evidence of irregular financial or delivery issues arises. This could include, but is not limited to, non-delivery of training when funds have been paid, sanctions imposed by an awarding organisation, allegations of fraud, an inadequate Ofsted grade, not meeting relevant QAA quality code indicators, allegations or complaints by apprentices, employers, staff members, or other relevant parties
- The subcontractor must not use ESFA funding to make bids for, or claims from, any European funding on their own behalf or on our behalf.
- They must not use payments made by ESFA as match funding for ESF projects.
Statement approved by Head of Apprenticeships, Solent University
October 2019
Annex 1
Extract from Apprenticeship funding rules for main providers, August 2019 to July 2020,
Version 1 explaining the content of our employer contracts regarding the use of subcontractors
“If you and an employer agree the use of delivery subcontractors, you must have an up-to-date written agreement in place with each employer that sets out the following for the delivery of their apprenticeship programme:
P180.1 The apprenticeship training and/or on-programme assessment that you will directly deliver.
P180.2 The amount of funding you will retain for your direct delivery.
P180.3 The apprenticeship training and/or on-programme assessment that each delivery subcontractor will contribute to the employer’s apprenticeship programme.
P180.4 The amount of funding you will pay each delivery subcontractor for their contribution.
P180.5 The specific amount of funding you will retain to manage and monitor each delivery subcontractor.
P180.6 The specific amount of funding you will retain for each other support activity you will provide to each delivery subcontractor.
P180.7 The specific amount of funding you will retain for the monitoring you will undertake to ensure the quality of the apprentice training and/or on programme assessment you have contracted each delivery subcontractor to carry out.
P180.8 A detailed description of how the funding retained for each activity detailed in P180.5 to P180.7 contributes to delivering high quality training and how the funding retained is reasonable and proportionate to delivery of the apprenticeship training described in P180.3.
P180.9 Any actual or perceived conflict of interest between you and any delivery subcontractors. For example, where you and a delivery subcontractor are part of the same group, share common directors or senior personnel, or where you will benefit financially from using a particular delivery subcontractor.”
