Subcontracting Policy for First Intuition

Subcontracting at First Intuition

First Intuition work with apprentices and their employers to develop their individual technical and all-round skills that help businesses to thrive and grow. Our subcontracting policy aims to support this and ensure that apprentices are being offered the best programmes to support them on their journey. We are committed to working closely with our subcontracting partners to deliver excellence.

Purpose of Subcontracting

First Intuition subcontracts only in the following circumstances:

Where specialist provision is required to provide specialist courses to employers (section 1)
In a small number of cases where an employer provides training in house as part of an apprenticeship provision to its own employees (section 1)
At the request of employers to allow flexibility and access to First Intuition centres across the group where this offers a more convenient study centre or study route for the apprentice (section 2)

First Intuition will not enter into subcontracting relationships with the following providers:

Any provider not listed on the Register of Apprenticeship Training Providers
Any provider who is considered a higher-risk organisation as per the ESFA financial assurance guidelines
Any provider with an inadequate report from Ofsted¹

The due diligence process will enable us to make decisions based on the above.

Contract Managers

All employees responsible for contract management of cross-network subcontracting sit on the Compliance Network across First Intuition. External subcontractors are managed by individuals on the senior management education teams.

Reducing our subcontracted provision

First Intuition is aware of the requirement to work towards a reduction in subcontracted provision where possible. We believe that only subcontracting for the reasons above helps us to keep it to a minimum as well as ensure we are only subcontracting in the right circumstances for employers and learners. Where possible we will suggest employers work with our subcontractors directly to avoid subcontracted provision.

SECTION 1: Subcontracting outside of the First Intuition Network

Programme setup

First Intuition will clearly state the following for each employer that we work with:

The apprenticeship training and/or on-programme assessment that we will directly deliver
The amount of funding that we will retain for our direct delivery
The apprenticeship training and/or on-programme assessment that each delivery subcontractor will contribute to the employer’s apprenticeship programme
The amount of funding we will pay each delivery subcontractor for their contribution
The amount of funding we will retain to manage and monitor each delivery subcontractor
The specific amount of funding we will retain for each other support activity we will provide to each delivery subcontractor
The specific amount of funding we will retain for the monitoring we will undertake to ensure the quality of the apprentice training and/or on programme assessment we have contracted each delivery subcontractor to carry out
A detailed description of how the funding retained for each activity detailed contributes to delivering high quality training and how the funding retained is reasonable and proportionate to delivery of the apprenticeship training
Any actual or perceived conflict of interest between us and any delivery subcontractors

Improving teaching and learning

We carry out a regular and substantial programme of quality assurance in order to monitor the delivery of the subcontractors we are working with, both for their training and on-programme assessment. This involves observations of teaching, learning and assessment which are all tracked accordingly. We work with our subcontractors in order to ensure continuous improvement is taking place in the classroom and the impact on the learners is positive as well as allowing them to progress successfully on their apprenticeship programmes. A governance structure is in place to ensure consistent and valuable communication.

The benefits offered by First Intuition subcontracting arrangements

First Intuition has agreed to subcontract specialist Tax Courses to Lexis Nexis (RELX Limited). This is because many employers in the accountancy sector require employees to complete the apprenticeship standards following either a tax or an accountancy pathway. First Intuition can support apprentices in the development of their skills and behaviours in a finance environment and provide access to specialist tax training delivered by Lexis Nexis. Other specialist providers may be introduced if, after careful consideration, this is believed to be in line with First Intuition values and of benefit to the employers and apprentices working with First Intuition.

First Intuition may agree for certain clients to subcontract the skills and behaviours training back to the employer. This is in the case of employers who have Employer Provider status. Such programmes are mapped in detail to the level 4 and level 7 standards and subcontracted on an actual cost basis. This allows the employer the flexibility in creating a scheme providing the apprentices with all the support necessary to thrive in their working lives. The delivery of this kind of programme will be monitored as part of an overall programme that we control.

Subcontracting to the employer allows for the skills and behaviours training to be delivered in context for the learners (the context being their employer’s work practices and systems) as well as for Skills and Behaviours training to be delivered by expert “practitioners” e.g., more experienced employer staff who understand the relevant culture, career paths, expectations and client base.

Management Fees and support

The support provided will vary on a case-by-case basis but may include:

Completing client and apprentice sign up process
Input of data onto the ILR
Managing payments to the subcontractor
Collecting co-investment payment from the employer
Sampling of subcontractor learners
Due diligence and quality assurance procedures
Sharing good practice
Account management meetings
Observations of teaching, learning and assessment
Support during Ofsted inspections and audit
Monitoring completion data and KPIs
Providing on programme support and skills training to the apprentice
Carrying out progress reviews and monitoring progress of apprentices
Reporting to employers on progress
Support in passing through the Gateway and in preparing for the End Point Assessment
Advice and guidance on post pandemic recovery strategy

The fees charged will be agreed on a case-by-case basis depending on the extent of services provided. This will include business factors such as:

The level and type of professional training provided
The level of on programme support provided to the apprentice and the employer
The level of support provided to the subcontractor
The commercial relationship between the parties
The number of apprentices

The management fee will be between 0 and 15% of the funded costs.

Payment policy

Payment policy will be agreed on a case-by-case basis and will be either;

Paid upon invoice by the sub-contractor on completion of the course
Upon receipt of the funding from the ESFA on the basis agreed by both parties. In this case the payment to subcontractors will be outcome related

SECTION 2: Subcontracting across First Intuition centres

The benefits offered by First Intuition subcontracting arrangements

First Intuition Centres follow the First Intuition delivery model. We are part of the same group of companies but do not share delivery personnel. Subcontracting within the group allows employers to deal with one provider even if they have several locations. This provides easy administration and consistent apprenticeship delivery across a number of locations. In some cases, subcontracting facilitates greater flexibility of study options and dates for the apprentice and allows employers to meet business needs.

Programme setup

Each First Intuition centre will have the appropriate contracts in place with the other centres and these will be reviewed on an annual basis in October each year.

Due diligence will be reviewed annually in October and covers entity information and confirmation of safeguarding contacts. First Intuition centres have shared policies with respect to safeguarding, health and safety, equality, diversity and inclusion and all apprenticeship specific policies (which can be found in the apprentice handbook).

Each First Intuition centre will clearly state the following for each of the other FI centres where subcontracting is in place:

The apprenticeship training and/or on-programme assessment that will directly be delivered by the main
The amount of funding that the main will retain for direct delivery
The apprenticeship training and/or on-programme assessment that each centre will contribute to the employer’s apprenticeship programme
The amount of funding the main will pay each delivery subcontractor for their contribution
The amount of funding the main will retain to manage and monitor each delivery subcontractor

The learner planner will show costings for all elements of the programme to allow full transparency. It has been agreed that the invoice price will be the amount shown on the individual apprentice planner prepared by the Main provider.

Any conflict of interest is mitigated in how we price the elements of our apprenticeship programmes and the transparent pricing as agreed above.

Improving teaching and learning

First Intuition has robust arrangements in place to share knowledge and develop best practice in the delivery of teaching and learning. Through the network, feedback is collected from both employers and apprentices and shared across the group. Data and outcomes are monitored, and steps taken to facilitate the raising of standards across the First Intuition Group of companies. Each centre is a member of the FI Quality Network which meets on a monthly basis to share best practice and discuss anything relating to subcontracting.

For specific learner queries First Intuition centres will contact each other accordingly. There will be two observations per centre in any funding year. One will be completed solo and the other will be a joint observation. The decision as to whether any further observations are required will be taken on a standard risk-based approach depending on observation feedback.

Reporting

The following will be reported to the Main from the subcontractor on a timely basis depending on learner activity:

Attendance (on the day absences and overall attendance confirmation following course)
Mock scores
Course exams
Tutor comments (by exception)

Contingency planning

There is an FI Network contingency plan in place for any situation that may arise which compromises delivery at a centre location. Each individual FI Centre also have their own business continuity policy.

Review and publication

Created:	May 2018
Reviewed:	Jun 2021, Aug 2021, Feb 2022, Feb 2023, May 2023
Next Review:	Feb 2024