Subcontracting Policy

The purpose of this document is to define the basis on which any subcontracting arrangements will be managed. Where appropriate, Chiltern Training Ltd (CTL) will contract with other parties to deliver programmes and activities funded by the government through its funding bodies. The organisation with which it contracts will be subject to the requirements set out below.

The management of subcontractors will be based upon the application of the risk principle. All subcontractors will have a risk rating. This rating will determine the frequency and scope of the quality audits undertaken by CTL staff.

Due Diligence

Subcontractors will complete a CTL subcontractor application form with all relevant information requested to protect learners and to ensure the subcontractor is a legally, financially and educationally sound organisation, prior to a contract being signed.

Delivery Quality

Subcontractors will ensure that all learners are given an induction prior to their courses or programme. The induction given must be consistent with the standards specified in CTL induction policy.

All courses should include an initial assessment process that enables learners and staff to identify what they want to achieve from the course. This process should ensure that:

•Learners have the necessary aptitudes, attributes and abilities to help them successfully complete the courses for which they are applying.

•Any learning support needs are accurately identified.

•Learners have the information they need to help them make well informed judgements about the relevance of their courses to their short and longer term employment and learning goals.

Any identified support needs will be fed back to CTL, who will approve the additional support and any extra cost involved. Subcontractors must have access to appropriate learner support arrangements.

Where appropriate the assessment should also gather necessary information about health and medical records, previous relevant experience, depending on the nature of the course itself and specifically where the nature of the course presents significant health and safety issues. CTL Health & Safety policy and risk assessments must be adhered to. All placements must be vetted prior to apprentices being placed there and an original copy of the check sent to CTL.

Tutors/Assessors must maintain learner progress records at an appropriate level of detail, in relation to the context and length of the course or programme. CTL review file documents provide the benchmark for the detail of records required.

All courses will have their content defined within a scheme of work and their sessions will be planned using an appropriate lesson/session plan. Both these should be consistent with the requirements defined in CTL Quality documents. CTL staff will observe one induction and one teaching & learning session per year as a minimum and subcontractors will be required to observe their staff as per CTL quality timetables.

Subcontractors will register their learners with the appropriate examination boards within agreed timescales and abide by awarding body regulations. Subcontractors will maintain assessment and verification, and/or moderation arrangements that are consistent with the requirements of the awarding bodies, examination boards and the Sector Skills Councils, where the latter make recommendations regarding assessment and verification arrangements.

Subcontractors will ensure that they maintain effective learner and employer engagement. CTL will write to each learner when they commence programme and will survey learners and employers each year.

Health & Safety

Subcontractors must provide details on request to CTL, of how they ensure that facilities used to deliver learning meet all Health & Safety regulatory and legislative requirements, including where required specific health & safety reports, audits and risk assessments.

Subcontractor tutors must be capable of and must undertake activity and facility risk assessments at a frequency consistent with the type of activity and the nature of the facility being used.

Information, Advice and Guidance

Subcontractors will be required to demonstrate that they provide information, advice and guidance (IAG) at an appropriate range of venues and through a range of media, including the internet, to a standard consistent with that offered by CTL. Subcontractors are also required to achieve and maintain Matrix accreditation. IAG should include:

- Initial advice and guidance to inform the learner’s choice of programme or course

programme advice and guidance to help learners

- Develop ideas for future learning or employment

- Who have personal issues such as substance misuse, housing problems, pregnancy etc, identify and make contact with relevant organisations

- Make specific choices about future learning or employment.

Facilities and Resources

All facilities and resources used must be “fit for purpose” and comply with all current Health & Safety legislation.

Self-Assessment

All subcontractors will be required to undertake a self-assessment process in relation to the Common Inspection Framework and produce a SAR which clearly and specifically identifies and evaluates the courses and programmes which they are contracted to deliver. The SAR and resulting action plan must be submitted as specified in the contract.

Safeguarding

Subcontractors will be required to have in place safeguarding arrangements which are consistent with the standards specified in the guidance documentation provided by CTL.

Audit Procedures

CTL will conduct quality audits of subcontractors as specified in the in annual contract schedules. CTL will provide reasonable advance notice in writing of proposed visits to the subcontractor of the scope and date of each audit.

Post-audit action plans will be produced where necessary and Subcontractors will be supported through training and mentoring to achieve the aims set out in the action plans. Subcontractors who consistently fail to attend training or engage in the mentoring scheme will be financially penalised.

Policy and Procedures

Subcontractors will be required to demonstrate that they have robust quality audit arrangements, consistent with the requirements related to the audit activities undertaken by CTL as specified above. They will be required to maintain, review and update policies and procedures in line with national legislation and as appropriate to the nature of their contract in the following areas:

•Health & Safety

•Equality & Diversity

•Safeguarding

•Sustainability

•Quality Assurance, including performance monitoring and development of:

- Teaching practice Initial assessment

- Additional learning support, Information, advice and guidance

- Self-assessment

- Service standards

•Performance management information

•Data protection

•Staff recruitment and development

•Financial management

Contract Monitoring and Review

Subcontractor performance will be monitored on an ongoing basis. Feedback on performance will be provided in writing, by phone or e-mail. The methods used will depend upon the circumstances at any point in time. Feedback will also be provided at contract performance review meetings. The frequency of these meetings will depend upon the performance of the subcontractor.

Where performance falls below the standard required, subcontractors will be issued with a notice to improve. Support will be provided to help subcontractors develop and enhance the quality of their delivery. If a subcontractor fails to meet the necessary improvements within the agreed timescales, it may be necessary to implement contract termination procedures.

Contact Termination

CTL will work with its Subcontractors to ensure that all learners receive high quality, engaging and safe training, with all the necessary support for individuals to achieve their aims.

Should a Subcontractor consistently fail to improve any element of its performance which is deemed to be unsatisfactory or inadequate, or consistently fail to engage in training or with the quality support systems which are in place, CTL reserves the right to terminate the contract to protect the learners.

If contract termination procedures are implemented, subcontractors are contractually required to co-operate fully with this process. Failure to comply with the requirements will result in significant penalties.

You can view our last two years subcontracting report by clicking here.

Supply-Chain Fees and Charges Policy

Policy Statement

The purpose of this policy is to provide consistency of approach and transparency to the CTL’s supply-chain fees and charges in relation to its subcontracted provision.

Scope

This policy will apply to all sub-contracted training activity undertaken by CTL.

Key Principles

This policy will be implemented in a manner that embraces our key principles of: developing a culture of honest and open communication; encouraging creativity and innovation; recognising and celebrating achievement; Striving to monitor, improve and review performance and Customer Care and Putting learners and customers at the heart of everything we do. Chiltern are committed to work and serve the interests and demands of the local community this may include working in partnership with subcontractors, where it can be demonstrated that this would deliver extra value to learners and employers. Chiltern’s main purpose for subcontracting will be to diversify and extend its offer and to expand its offer geographically. Chiltern Training will only sub-contract where provision is mutually beneficial and is based on joint partnership working to deliver first class provision to learners.

Chiltern will issue any sub-contracting opportunities on its website should it wish to tender any provision. Partners Selection Sub-contracting partners will be selected using a robust due diligence process. Subcontractors will be required to supply Chiltern with all relevant information requested to protect learners and to ensure the subcontractor is a legally, financially and an educationally sound organisation, prior to any contract being signed. Chiltern will set standards and performance levels required and will ensure that partners fully understand their commitments.

Quality Monitoring

Fees Standard Management Fee

This fee is applied to all subcontracted contracts, and is the proportion of SFA/Loans funding retained by Chiltern to cover standard costs incurred through its management of these contracts. These costs include:

Administration

Quality assurance and monitoring

MIS functions relating to the submission of funding claims to the SFA

Provision of a dedicated Account Manager including attendance at management meetings

Due Diligence support, guidance and checking

Training and Development – including access to CPD activities.

The current management fee is 20% reviewed annually. All fees will be agreed with subcontractors prior to the issuing of contracts, and will be reviewed prior to annual re-contracting.

Payment

Chiltern will make payments by the end of each calendar month. This payment will be made by BACS transfer. However, if any supporting evidence is queried by Chiltern then payment will be withheld until these queries are resolved, and payment will then be made at the earliest possible opportunity.

Monitoring and review

Chiltern will review this policy annually. This review will take place in July of each year, and any policy revisions will be completed and published prior to the commencement of the next academic year. Any changes to the policy will be communicated to existing subcontractors at contract management meetings. Furthermore, Chiltern will distribute a copy of this policy to all potential new subcontractors and discuss it with them as part of Chiltern ’s pre-contracting process.