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This policy outlines SPS’s approach to all supply chain / sub-contracted partner activity supported by funds received from the Education Skills Funding Agency (ESFA) and the fees and charges applied to these arrangements.
This Policy is a mandatory requirement of the ESFA that must be in place prior to SPS participating in any supply chain / sub-contracted partner activity during the 2021 – 2022 Academic Year (1st August 2021 to 31 July 2022)
2. GENERAL PRINCIPLES
SPS will use subcontractors (supply chains) to optimise the effectiveness of its service delivery and will ensure that:
- Subcontracting aligns with the SPS strategic objectives and delivery plans
- SPS undertakes fair and transparent selection of supply chain and ensures full due diligence is completed before the award of any contracts
- SPS and its potential partners have agreed values towards the provision of education and training
3. BASIS FOR USE OF SUBCONTRACTED PARTNERS
Wherever possible, SPS Training will provide all of the training it has been contracted to deliver. Where this is not possible and SPS enters into subcontracted/supply chain arrangement, it will ensure that we either:
- Work with partners who are able to attract learners and employers that SPS would otherwise have not been able to attract.
- Ensure supply chain/sub-contracted partners offer a different curriculum to that which SPS currently offer
- Work with supply chain/sub-contracted partners who are able to penetrate a different geographical area to that in which SPS currently work
- Provide immediate subcontracted provision whilst expanding direct capacity. This might include working with supply chain/sub-contracted partners to research and learn prior to making any significant investment in resources linked to its own direct delivery.
- Work with supply chain/sub-contracted partners who can provide small scale responsive niche delivery where the cost of developing direct delivery would be inappropriate to SPS.
- Support employers who operate across a wider operational / geographical footprint.
4. SUPPORT SERVICES OFFERED TO SUPPLY CHAIN/SUB-CONTRACTED PARTNERS
SPS will work closely with supply chain/sub-contracted partners to ensure that delivery of training is effective and of a high quality. SPS will work closely with partners to offer services such as:
- Annual due diligence checks
- Pre contract engagement activities (EOI evaluation and contract negotiation)
- Performance Reviews
- Performance action planning and Improvement planning
- Management of the ILR including data input and the supply of monthly reports
- Web provision of electronic registers
- Safeguarding advice
- Observation and Improvement of Teaching, Learning and Assessment
- SAR/QIP Advice
- Complaints support and investigation
- Legal and Financial compliance
- Surveys of Learners
Specific costings are agreed at point of contract and are informed by:
- Knowledge of funding and ILR rules
- Quality of paperwork
- Risk Rating
- Performance Track Record
- SAR grades
- Effectiveness of Teaching, Learning and Assessment
- Programme Type and Length
- Learner Volume
5. QUALITY ASSURANCE AND AUDITS
he quality of supply chain/sub-contracted partners delivery will be monitored as part of the SPS quality framework. As such quality audits and observations will be carried out regularly to ensure that subcontracted provision is in line with direct delivery.
In year monitoring and contractual compliance is regularly completed and actions for improvements in teaching, learning and assessment or in operational controls are reviewed as part of this process.
SPS will frequently audit the quality of learner paperwork to ensure that these are contractually compliant and meet the requirements of the funding rules.
6. FEES AND CHARGES
SPS will usually retain a fee of between 15% and 20% of funding offered for providing the services previously mentioned in this policy. In some cases, the fee may be higher should additionally support and development be required.
The percentage applied to each supply chain/sub-contracted partner will be determined by:
- The level of support needed by the supply chain/sub-contracted partner in relation to the services provided by SPS.
- The funding required by the supply chain/sub-contracted partner to enable sustainable and high-quality provision to be delivered.
The fee will represent the cost that SPS incurs in effectively identifying, selecting and managing all supply chain/sub-contracted partners.
Further charges to cover additional costs may be added (on a case-by-case basis) to the base fee to meet the cost to SPS of any additional support that SPS deems necessary to ensure the quality of teaching, learning and assessment and achievement of success rates are effectively met.
7. PAYMENT TERMS
SPS will pay its supply chain/sub-contracted partners in accordance with its contract. This will usually be:
- An invoice request within 10 working days of the ILR upload deadline date
- The fee will be deducted from the monthly ILR earned amounts
- Supporting documentation is made available for the payment which would satisfy the requirements of a funding body audit. Payment may be retained until the Audit requirements have been met
- The total value of payments will be restricted to the contracts maximum contract value
- Payments will be made to supply chain/sub-contracted partners within 30 days of receipt of a valid invoice that compiles with the above points
8. POLICY REVIEW
This policy will be reviewed in accordance with ESFA Funding Rules. This policy will be reviewed and updated at least annually.
Should the ESFA Funding Rules change following publication in such a manner as to contradict this policy then the ESFA position will take precedence.
9. POLICY PUBLICATION
This policy will be published on the SPS website prior to launch of our subcontracting.