Apprenticeships Subcontracting Policy

Definitions and Scope

1. In accordance with the ESFA Funding Rules this Policy outlines the subcontracting arrangements for Northeastern University (the University’s) apprenticeship provision. The University will use subcontracted provision to enhance the opportunities available to apprentices and fill any gaps in niche or expert provision that the University identifies.
2. As defined by the ESFA Funding Rules, the following definitions apply:
   1. Subcontracting: Any delivery of an apprentice’s programme of learning by a separate legal entity. It does not matter if this is by a third party recruited to deliver on site (travel to teach), online learning or whether the delivery is described as a service.
   2. Subcontractor: A separate legal entity or an individual that has an agreement (called a Subcontract) with the University to deliver any element of the education and training funded by the ESFA. A separate legal entity includes companies in the University’s group, other associated companies, and sole traders. An individual could include a person who is a sole trader, self-employed or employed by an agency unless those individuals are working under the University’s direct management and control in the same way as the University’s own employees.

General

University Responsibilities

3. The University will only consider Subcontracting Provision that is an enhancement to its current programmes, specialist provision or otherwise outside of current Academic Faculty’s scope or capacity.
4. The University recognises its responsibility to conduct transparent and robust due diligence procedures on potential subcontractors to ensure compliance with the applicable funding rules and policy intent.
5. The University will monitor and evaluate not only the quality of subcontracted provision, safety and wellbeing of apprentices undertaking Subcontracted Provision, but also currency of the Subcontracted Provision and value for money. This will be carefully monitored to ensure continuous improvement and the best use of available funds.
6. All funding claimed and retained by the University will be clearly documented and agreed by all parties.
7. The ESFA’s rules governing subcontracted delivery are designed to increase the quality of provision and to ensure that employers have a direct relationship with their main provider. As the main training provider, the University will:
   1. Agree the use of Subcontractors with employers at the start of an apprenticeship.
   2. Carry out due diligence checks on potential delivery Subcontractors.
   3. Enter into a written agreement with Subcontractors.
   4. Ensure that second-level Subcontracting does not take place.
   5. Obtain an annual report from an external auditor if the total apprenticeship contract value exceeds £100,000 in any one financial year.
   6. Directly deliver part of the apprenticeship programme that is of substance.
   7. Maintain the relationship with the employer.
   8. Take full responsibility for the quality of all aspects of delivery and carry out regular quality assurance checks of Subcontractor’s Provision.
   9. Provide delivery sub-contractor declarations in line with ESFA dates and manage updates if arrangements or circumstances change during the year.

Individual Staff Responsibilities

8. The University’s main contact in regard to apprenticeship Subcontracting is Operations and Quality Assurance Manager.
9. The Operations and Quality Assurance Manager is responsible for the contractual arrangements with the Subcontractor and compliance with ESFA Funding Rules.
10. The Programmes Director will oversee and hold overall responsibility for the selection and verification of subcontractor suitability.
11. The individual Programme Lead will identify opportunities for subcontracting within their programme and contribute to the research and selection of appropriate subcontractors fit for purpose.
12. The Director of Business and Partnership Development & Apprenticeships holds the overall responsibility for Subcontracting, compliance, and declarations through the contract with ESFA.

Student responsibilities

13. Apprentices must treat Subcontractors with courtesy and respect both on and off University premises, in person and online.
14. Apprentices are expected to attend all courses where Subcontracting Provision is delivered in order to successfully pass the course, and/or gain the relevant micro certification, award, or qualification from the subcontracted organisation.

Monitoring and Reviewing

15. This Policy will be monitored, reviewed annually, and published by 31 October each year.
16. The Operations and Quality Manager and relevant contributors review this Policy and associated procedures on an ongoing basis, and make recommendations to Executive Committee as appropriate.
17. Executive Committee reviews this Policy for effectiveness.

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