2017 -2018 Funding Rules
It seems such a long time since the new funding rules where announced for 2017 - 2018 funding year, but as yet haven't been in force due to the non levy procurement and Adult Education Budget delays.
As you know existing contracts where extended and the previous subcontracting rules are to continue until the new contracts for non levy delivery are awarded.
These are covered in Apprenticeship funding and performance management rules - addendum 1 which apply from 1st May to 31st December 2017.
The ESFA will announce the contracts to successful applicants in December for a 'hit the ground running' start in January 2018.
Subcontracting Rules for Apprenticeships
As the 2017-2018 funding rules start as of January 2018, along with the non-levy contracts, I thought I would take another look at the main changes.
• As the main provider you are responsible for the relationship with the employer.
"You must maintain the relationship with each employer at all times. You must not allow a delivery subcontractor to lead that relationship."
P132 Page 21 Apprenticeship funding and performance-management rules for training providers v4
• As a main provider you must directly deliver some of the apprenticeship training and are not allowed to subcontract it all out.
"At the outset of each apprenticeship, a main provider and employer will agree a plan for its delivery. You must directly deliver some of the apprenticeship training and/or on-programme assessment associated with each employer’s apprenticeship programme. By apprenticeship programme we mean the apprentices that are being trained for the employer that has chosen you. The volume of training and/or on-programme assessment that you directly deliver for each employer must have some substance and must not be a token amount to satisfy this rule. It must not be limited to a brief input at the start of each employer’s programme or involve delivery to just a few of a large number of apprentices."
P123 Page 20 Apprenticeship funding and performance-management rules for training providers v4
• Subcontractors must only be used to complement your own apprenticeship delivery.
"You can use delivery subcontractors to complement your own delivery if requested by an employer and agreed at the start of an apprenticeship. Delivery subcontractors can deliver full or part-apprenticeship frameworks and standards."
P125 Page 20 Apprenticeship funding and performance-management rules for training providers v4
Point to Note:
As a Main Provider on RoATP you can deliver apprenticeships as a
Main or Supporting provider.
Subcontracting Rules for Advanced Learner Loans
There are also new funding rules regarding subcontracting available on the slides from the Advanced learner loans webinar - July 2017 and the main documentation: Advanced learner loans funding rules 2017 to 2018.
Funding Rules key changes:
• Reduction in the number of guided learning hours for designated qualifications at Levels 4, 5 and 6.
• Providers must recruit loans learners directly and not engage a broker or third party to recruit loans learners on their
behalf.
• Delivery of loans-funded provision must be done directly – subcontracting is not permitted. To support this direct centre
approval or direct qualification approval from an Awarding Organisation must be held.
• Learner eligibility extended to members of the UK armed forces serving overseas, and family members living with them,
who are aged 19+.
Subcontracting Rules for Adult Education Budget
There are also new funding rules regarding subcontracting from an AEB contract as covered in the Adult education budget webinar - July 2017:
• Reduction in level of subcontracting
• Sector-wide transparency
• Second level subcontracting not allowed from 1 August
• Key requirements:
- secure permissions to subcontract for the first time
- publish subcontracting fees and charges
- declare subcontracting arrangements to us twice a year.
All the new rules are covered in the Adult education budget: funding and performance management rules 2017 to 2018 documentation.
Ofsted Obligations for Subcontractors
There are several points to note in the Further education and skills inspection handbook Further education and skills inspection handbook for use from 4th September 2017.
Even as a subcontractor you will be in scope for inspection when your main provider is inspected or individually on your subcontracted provision.
"As part of the inspection, inspectors may inspect any provision carried out on behalf of the provider through subcontract(s) or partnership arrangements, including by subcontractors that hold additional direct contracts of their own. Typically, inspection visits to, or communications with, subcontractors that are in scope are likely to include the inspection of the direct contract holder’s arrangements to quality assure and improve the provision."
Further education and skills inspection handbook Further education and skills inspection handbook Point 34, Page 10.
Basically you can't avoid Ofsted!
“Ofsted reserves the right to inspect and grade any subcontractor and its provision as a separate entity against this framework and handbook.”
Further education and skills inspection handbook Further education and skills inspection handbook."
New Providers
As a Main Provider on RoATP you can deliver apprenticeships as a Main or Supporting provider.
"Where a provider comes into the scope of Ofsted inspection, for example when a provider gains a new contract with, or grant or loans facility from, the Secretary of State for Education, the Education and Skills Funding Agency (ESFA)8 or predecessor funding agencies or because of funding through the apprenticeship levy, it will normally be inspected within three years of the start of the contract or grant or drawing down of funding."
