HWGTA Subcontracting Policy (Apprenticeships)
Policy Statement
This policy sets out HWGTA’s approach to subcontracting apprenticeship provision in compliance with Department for Education Apprenticeship funding rules. This policy ensures transparency, quality, and value for money in all subcontracting arrangements.
Rationale for Subcontracting
Subcontracting of provision will only occur where it adds clear value to employers and learners and where HWGTA provision would otherwise be unavailable. Subcontracting will achieve the following:
- Enable the local provision of level 4 engineering apprenticeships in Herefordshire and Worcestershire, that are not currently available.
- Meeting the needs of local employers, who are seeking level 4 engineering provision, yet HWGTA cannot deliver the HTQ/HNC element of the apprenticeship.
- Provides specialist access to expertise of engineering HTQ/HNC qualifications.
- Support local capacity building and learner choice, while maintaining quality standards
Scope
This policy applies to all subcontracted apprenticeship training funded through the apprenticeship funding system of the Department for Education.
Responsibilities
A formal and legally binding Subcontracting Agreement will be in place between HWGTA and the Subcontractor before any provision commences. The contract will define clear responsibilities, termination clauses, and compliance requirements.
It is the responsibility of HWGTA to agree the use of Subcontractors with the Employer.
Due Diligence
Before entering any subcontracting arrangement, HWGTA will:
- Ensure the Subcontractor has a proven track record of high-quality delivery, capacity to meet employer and learner needs, and demonstrable experience of DfE and AO requirements.
- Verify that subcontractors are listed on the Apprenticeship Provider and Assessment Register (APAR).
- Ensure subcontractors hold an existing Ofsted grade 1 or 2 outcome or achieve Expected Standard or higher at future inspections.
- Conduct financial health checks, seek confirmation of financial compliance with apprenticeship funding rules.
- Review safeguarding and prevent arrangements.
- Confirm no extremist affiliations or conflicts of interest exist.
- Ensure HWGTA and the Subcontractor have put in place and agreed comprehensive arrangements for employer and learner communication, training delivery, quality assurance, safeguarding, ED&I, financial arrangements, reviews, and compliance.
Quality Assurance
HWGTA will implement a robust and rigorous QA framework including:
- Regular observations of teaching and learning, or examination of the subcontractors own observation records.
- Learner and employer feedback surveys.
- Regular reviews of the subcontracted provision with learners.
- Annual audits and compliance checks to ensure arrangements are being implemented.
- Reviews of retention, achievement rates and grade attainment.
Delivery Arrangements
Detailed delivery arrangements including training plans will be developed in collaboration between HWGTA and the Subcontractor.
HWGTA are the main provider and will:
- Inform learners and employers of the roles of HWGTA and the Subcontractor.
- Carry out all pre-start assessment, compliance and onboarding.
- Hold the ILR records and ensure they accurately reflect subcontracted provision.
- Plan and monitor on and off-the-job training.
- Carry out frequent, regular in-company reviews with the learner and employer.
- Manage learner behaviour and attendance, involving the subcontractor and employer where necessary.
- Make all arrangements for apprenticeship assessment.
The Subcontractor will:
- Provide access, information and evidence as reasonably required by HWGTA and/or the DfE to conduct appropriate due diligence or audit.
- Work closely with HWGTA to plan, deliver, and assess level 4 HTQ/HNC Engineering qualifications.
- Provide appropriate resources including software, training materials, textbooks, to deliver the qualifications.
- Provide suitable reports on learner progress, attainment, attendance and behaviour to HWGTA.
Safeguarding and Prevent
HWGTA is committed to safeguarding learners deemed to be children or vulnerable adults, through the implementation of the Safeguarding and Prevent Policy.
It is the responsibility of both HWGTA and the Subcontractor to provide a safe environment for learners. To ensure this, HWGTA requires Subcontractors to ensure and evidence:
- There is an effective safeguarding policy and procedures in place
- There is an effective prevent policy and procedures in place
- There is a designated person who deals with safeguarding
- There are effective measures to ensure safer recruitment for staff
Services and Fees
HWGTA will deliver most of the apprenticeship standard and therefore retain the majority of the apprenticeship funding. A management fee will not be charged as costs to administer the subcontracting arrangement will be covered by the funding received and utilised for HWGTA’s role in delivering the standard.
The Subcontractor price and payment structure will be agreed separately and recorded in, or as an appendix to, the Subcontracting Agreement.