Working in Partnership - Qube Learning€¦ · POL0016 Working in Partnership V1 20191129 Quality Assurance Processes 70% Best Practice Sharing - Regular Updates Qube Learning aims

Registered in England: 2887289 Registered office: 7 Park Square, Milton Park, Abingdon, Oxon, OX14 4RR

POL0016 Working in Partnership V1 20191129

Working in Partnership

A guide to the Policies and Procedures for Supply Chain

Management of Qube Learning Sub-Contractors


Introduction The purpose of this document is to provide transparency of Qube Learning’s approach to subcontracting procedures, the selection of partners, fee retention and support afforded to partners. Qube Learning is committed to ensuring that the maximum amount of funding possible is passed onto partners to maximise the quality of the learning experience for all students.

Background Qube Learning has worked with partners since 2006, known as Qube Partner Providers (QPP’s). Qube Learning understands how important it is to work with National and SME employers to ensure their internal development and training priorities, as well as those of the LEP’s, are met. Subcontracting accounts for a small proportion of Qube Learning’s overall delivery. Our strategy is to ensure that the QPPs we work with offer diverse and high-quality provision to meet the needs of their local areas. Enabling us to build strong bids for future tenders to meet future government priority requirements. We believe that effective subcontracting has benefits for all stakeholders, we therefore ensure that all QPP’s are committed to achieving both the objectives defined in our business plan and the priorities of the Education and Skills Funding Agency (ESFA). The Partner Relationship Manager oversees and has accountability for QPP performance, however decisions are made in partnership with the MI Director and Chief Executive Officer, as well as other Executive and Non-Executive Board members where applicable. Individuals with direct roles in Partner Management: Joe Crossley Chief Executive Officer Adam Baker MI Director Belinda Richards Partner Relationship Manager Vikki Wilson Head of Compliance Data Team Process partner data onto Qube Learning’s MIS External Auditor Financial Assurance / Funding Compliance Individuals with indirect roles in Partner Management: Rob Horspool Chief Financial Officer Adrian Grove Business Development Director Amanda Locke Head of Quality Different types of ‘supply chain’ arrangements exist as defined in the below table:

Prime Contractor The principle contract holder is at primary level and identifies their internal capacity and capability, and any gaps are delivered through a sub-contract.

Sub-contractor The sub-contract holder is at secondary level. The sub-contractor delivers components of the main contract either for a prime, managing agent or consortium.

Provision sub-contract A prime contractor has agreed a sub-contract with a provider and allocated part of their provision. The sub-contractor will hold its own funded allocation profile to achieve starts and outcomes.

Services sub-contract A prime contractor subcontracts a specialism to a subcontractor as part of the wider programme.


The below table outlines Qube Learning's itemised costings for the management of partners within the 2019/20 academic year. The costings apply to all subcontracted training activity and have been established in accordance with the ESFA’s Apprenticeship Funding and Performance Management Rules for subcontracting compliance. As part of Qube Learning’s funding contract with the ESFA, we are required to submit details of sub-contracting arrangements by completing a ‘Declaration of Sub-contractors’ via the ESFA’s Hub portal. This specifies the amount of funding that will be paid to each partner in the relevant timeframe. On an annual basis Qube Learning submit a separate declaration of the fees retained via the ESFA’s Hub portal. Initial fees are set following a robust due diligence process and the percentage of funding retained by Qube Learning is based upon the costs associated with the management of sub-contracted provision, along with a fair and appropriate mark-up. The costs vary according to the type of provision, the deemed risk of the provision and data processing/maintenance costs. The costs are reviewed annually and include but are not limited to the following:

Governance 10%

Access to a team of experts for all functions Qube Learning ensures that from the outset of each partner relationship, the provision is sustainable and effective. Systematic processes are followed throughout an employer's apprenticeship programme to ensure each partner remains a going concern whilst still delivering to Qube Learning's high standards. Each Governance activity listed ensures the delivery partner is operating within all Governing body requirements. As the main provider, Qube Learning has visibility of regulation updates which are subsequently distributed to and discussed with partners. The funding retained is fair and proportionate to the overall delivery as it ensures the employer's apprenticeship programme remains compliant, feasible, consistent and robust. In the unlikely event of a partner going into Administration, Qube Learning ensure that contingency planning is in place to alleviate any potential disruption to the Apprenticeship programme.

Contract delivery guidance ensuring ESFA funding rules are met

Contract establishment Director Checks

Due Diligence risk assessment and status updates

Funding rule updates, training and guidance

Preparation for External Inspection Profile planning, review and performance management

Management Information Systems Processes 20%

Achievement rate data Prearranged external audit visits are undertaken with Partners on an annual basis, conducted by an external auditor on behalf of Qube Learning. A full audit report is generated following the audit activity which is reviewed in detail and shared with each partner. Audit and compliance is directly linked to the reputation of Qube Learning's subcontracted provision. Qube Learning manage all ESFA distributed funding reports, including monitoring the correct application of funding for all students through monthly ILR submissions. Qube Learning manages the risk of funding compliance and audit, enabling partners to focus on training our students, leading to a high quality provision.

Audit and follow up compliance support Data validation checks Employer eligibility and incentive payments

ILR processing of starts, on programme, leavers and completions

Issuing document templates

Ongoing compliance monitoring and support

PO & remittance preparation Reconciliations


Quality Assurance Processes 70%

Best Practice Sharing - Regular Updates Qube Learning aims to develop a professional, effective and mutually beneficial working relationship with each Partner. This ensures that every student has the best opportunity to reach their full potential, in line with their employer’s defined learning outcomes. Qube Learning works closely with each partner to continuously improve its overall quality and where applicable, highlight opportunities to increase the quality of teaching, learning and assessment in line with OFSTED, other external agencies and general good practice. Quality Assurance and monitoring visits, which are both prearranged and unannounced are undertaken with the partner in order to sample the partner’s records. Observation of Teaching, Learning and Assessment will occur and may include joint visits with the partner to observe a member of their delivery staff during a training session. These visits ensure that the partner is complying with Qube Learning’s reporting, statutory and quality assurance requirements. Student safety and awareness is of the upmost importance to Qube Learning, therefore in addition to undertaking mandatory DBS checks and in line with National priorities, Qube Learning provide frequent up to date training and support on Safeguarding, Prevent, Equality and Diversity and British values.

Curriculum development and delivery set up guidance

EPA/ EPAO Support External Audit Support

Learner voice strategies and improvement planning

Matrix accredited advice and guidance

Process Improvement Support (policies, procedures, forms)

Quality Assurance Sampling

Safeguarding, British Values, Equality and Diversity and Prevent training and support

Self-Assessment and Quality Improvement Support

Staff competence checks, including DBS

Student and Employer satisfaction surveys Teaching and Learning Observations

Process Detail Selecting a QPP The key principles of selecting a new QPP are whether their ideals align with the strategic objectives of Qube Learning, as below: 1. Bring positive local community benefits / widening participation – our QPP’s have good and in some cases

long standing relationships with their employer’s. By collaborating with the QPP and employer, Qube Learning are able to enhance the portfolio of programmes offered by the employer to their staff, therefore reducing the number of Providers the employer needs to engage with.

2. Add value to the work Qube Learning does – our QPP’s can offer specialist and niche programmes to employer’s and students through whole programme delivery or specialist training.

3. Complement but not compete with the existing product portfolio of Qube Learning. 4. Engage with QPP’s where it is not feasible to deliver a programme requested by the employer or are

aligned to key sectors that Qube Learning or Government has prioritised. 5. Have potential for grade 1 or 2 provision – this is established through observation of teaching, learning

and assessment and Ofsted grades, where applicable. 6. No significant issues identified following a thorough due diligence process with the QPP. 7. Have a track record of good achievement rate, where available.


8. Are willing to engage in a mutually supportive relationship built on trust and respect. 9. Have a good reputation and standing in the sector / market. 10. The relationship complies with the ESFA sub-contracting funding rules in effect at the time.

QPP’s may not further sub-contract provision, this is referred to as 2nd Tier Sub Contracting, which Qube Learning does not condone under any circumstances unless first approved by the ESFA.

Prior to Qube Learning participating in any subcontracting activity that is funded or co funded by an employer, Qube Learning will inform the student and employer of the following:

The Apprenticeship training and/or on-programme assessment that will be directly delivered by the QPP

The amount of funding to be retained for direct delivery of the Apprenticeship training and/or on-programme assessment that each QPP will contribute to the employer’s Apprenticeship programme

The amount of funding payable by Qube Learning to each QPP for their contribution

The amount of funding to be retained by Qube Learning to manage and monitor each QPP

The support that Qube Learning will provide to each QPP in exchange for the amount of funding retained

The monitoring that Qube Learning will undertake to ensure the quality of the apprenticeship training and/or on-programme assessment

Any actual or perceived conflict of interest between Qube Learning and any QPP’s Expression of Interest The first step of engagement is an expression of interest form, this logs details of all prospective providers who have approached or have been approached by Qube Learning to discuss a partnership, with initial findings and outcome. Initial checks are conducted, focussing on:

Website – does this look good is it up to date and informative? Do they display logos?

Companies House – are there any issues showing?

HSC Public Register of Prosecutions – has there been any notifications of H&S Breach or notifications to RIDDOR

ESFA site including RoATP, list of declared sub-contractors to identify if the prospective partner is receiving funding from others

ESFA current notices of concern and early termination lists

Ofsted inspection reports – has the partner provider been inspected in their own right, what was the grade, if not in their own right have they been inspected as part of a main providers inspection

UK Register of Learning Providers – is the partner provider registered? Does the address details match their website?

FE Choices results/Ofsted Learner Views – do these show any concerns? The register of apprenticeship providers will show the employer and learner satisfaction rates

During our initial checks, if any discrepancies are identified, these are investigated further prior to a final decision being made.


Due Diligence Should the expression of interest checks prove successful, we will undertake a thorough due diligence process. We review the potential partner’s suitability for high quality delivery, understanding and current levels of compliance with the ESFA Funding Rules, quality and overall capability in order to be in receipt of government funding, including the following key areas:

Statutory Accounts/ Financial Health, Director Review, Legal status & Credit Checks

Contract History

UKPRN and RoATP Registration

Capability and Capacity to deliver high quality training and assessment

Achievement Rates (Overall & Timely)

Ofsted & Awarding Body Reports

Policies & Procedures including PREVENT, Equality & Diversity, Environmental Sustainability

Arrangements for health and safety and safeguarding

Localism / Speciality

Links to extremist organisations, this is undertaken via the gov.uk page https://www.gov.uk/government/publications/current-list-of-designated-persons-terrorism-and-terrorist-financing

References Contracts In Line with the ESFA funding rules, all due diligence processes and contracts have been evaluated to ensure that they follow the Public Contracts Regulations 2015. The following terms are contained within all contracts: 1. Agreement date and parties 2. Definitions and interpretations 3. Commencement and duration 4. Subcontractors obligations 5. Changes to Services 6. Invoicing and Payment 7. Confidential Information 8. General Data Protection Regulations – Data Sharing 9. Ownership of Intellectual Property 10. Sub-Contractor Indemnity 11. Termination 12. Non Solicitation 13. General 14. Governing Law and Jurisdiction 15. Agreement 16. Definitions 17. Services and Charges

Communication Strategy The main principles of communicating with our QPP’s are through:

Regular Phone Calls and email communication

Review and OTLA meetings

Secure data transfer portals


It is important to maintain regular contact with our QPPs to ensure that:

All students are progressing to achieve their qualification in a timely manner.

Identify any problems or concerns that either party may have identified

Ensure all programmes are delivered according to funding and quality regulations Correspondence from these meetings, retained for auditing purposes, are:

Notes / minutes of meetings both internally with Manager/Board and with our QPP

Records of e-mails, correspondence etc.

Notes from audit / monitoring visits kept on file and shared with the QPP

Observations of teaching, learning and assessment

Managing Risk, Monitoring & Reviewing Performance The monitoring and review cycle will ensure a process of continuous improvement is made, allowing either Qube Learning or the QPP to have an open and honest approach to managing the quality of provision throughout the life of the contract. QPP’s are risk rated depending on the outcomes of our initial due diligence processes as stated above. In addition, our annual QPP reviews, OTLAs, and external audits with those approved for all Apprenticeships and/or Traineeships. Quality Improvement Framework Extract from ‘Quality Improvement Framework’ The quality improvement arrangements for sub-contracted provision ensure that the following aspects of the quality improvement framework are applied:

Programme approval

Inclusion in performance review, self-assessment and quality improvement planning

Assessment, internal and external quality assurance Client/stakeholder/ student evaluation

Observation of teaching and learning Quality assurance breaks into broadly two areas; the auditing of Qube Learning’s statutory reporting requirements to ensure that they are an accurate record; and the internal quality assurance process. The latter will be more reflective of a partnership between the QPP and Qube Learning to ensure high quality provision is delivered that is reflected by high retention and achievement rates. Quality Assurance Process Qube Learning aims to develop a professional and effective working relationship with its QPP’s, providing support and input on a partnership basis. We are passionate about continually improving the quality of everything we do, whilst ensuring that all students have the opportunity to reach their full potential. Qube Learning employ a dedicated Partner Relationship Manager whose role is to drive continuous improvement through practical guidance and support, including on site observation. The relationship should be mutually beneficial. For example, Qube Learning will work with the QPP to improve their overall quality and highlight opportunities to increase the quality of teaching, learning and assessment in line with OFSTED, awarding body, funding body and general good practice. Quality Assurance and OTLA’s will involve both prearranged and unannounced visits with the QPP in order to sample the QPP’s records. Observation of Teaching, Learning and Assessment will take place an may include joint visits with the QPP to observer a member of their delivery staff, both of these visits are to ensure that they meet Qube Learning’s reporting, statutory and quality assurance requirements.


Prearranged external audits will be agreed with the QPPs on an annual basis, conducted by an external agency on behalf of Qube Learning. The depth of review visits include but are not limited to:

QAR to data (if applicable) QAR is monitored monthly and copies sent to the QPP Data Managements HR Management Quality including Awarding Organisation updates, SAR and QIP Equality and Diversity promotion Safeguarding, Prevent and British Values promotion Health and \Safety Additional Student Support Functional Skills Support Updated to policies and procedures A discussion with delivery staff A discussion with students Checks on adequacy of resources Tracking of student progress via QPP e portfolio and/or monthly updates

Equality & Diversity, Safeguarding and Prevent To ensure all QPPs within Qube Learning’s supply chain are effectively promoting and implementing E&D, Safeguarding and Prevent, the following checks are undertaken, with QPPs monitored at regular intervals.

QPP’s must provide a copy of their Policies

QPP’s must undertake DBS checks on all staff, with information sent to Qube Learning annually, but immediately for any new delivery staff

QPP’s are sent Qube Learning’s E&D, Safeguarding and Prevent Policy

The contract will contain explicit reference to E&D policies, Safeguarding and DBS check requirements

All on-site assessments (Quality Assurance, Audit and Contractual) will record compliance as part of the assessment process

All QPP staff are required to undertake Safeguarding and Prevent Training, copies of certificates must be provided to Qube Learning

Any concerns are notified through Qube Learning’s reporting procedure

Qube Learning will regularly supply QPP’s with updates and training materials

Staff To ensure all staff are fully qualified to deliver Qube learning requests that:

Delivery staff CVs are provided to Qube Learning

Delivery staff must be qualified in accordance with sector requirements, unless agreed in advance

Copies of CPD must be sent to Qube Learning annually

Copies of DBS checks for all staff Student/ Employer Voice The views of our students and employers are of the upmost importance to Qube Learning, we therefore expect our QPP’s to fully engage with an evaluation and feedback process.

The student and employer voice will be captured using on-line surveys (FE Choices), on-programme and end of programme evaluations and learner voice meetings


The QPP will provide copies of student and employer feedback on a regular and timely basis to Qube Learning via review paperwork

Qube Learning will conduct its own surveys of student and employer views as part of the overall Quality policy which will include but not be limited to Safeguarding, Prevent, Equality and Diversity questions

Qube Learning holds ultimate responsibility for all aspects of the provision that it is contracted to deliver, including any elements that it chooses to sub-contract. The below table identifies the risks to both Qube Learning’s contract with the ESFA and the student/ employer receiving an unsatisfactory experience:

RISK IDENTIFIED DETAIL OF RISK

CAUSE IMPLICATION

Achieving poor achievement rates, reducing Qube Learning’s overall performance rates.

Insufficient quality assurance checks and student monitoring

Impact on Qube Learning’ performance statistics and overall Qualification Achievement Rates

Negative publicity associated with the QPP and generally putting Qube Learning’s reputation and achievement of contract in jeopardy.

Poor management of relationship, ESFA Audit or Ofsted Inspection

Loss of reputation, possible loss / reduction of ESFA contract

Not achieving funding targets, leading to lower than budgeted management fees and reductions in future allocation.

Under recruitment, poor contract management and performance checks

Achievement rates affected, poor quality of delivery, possible claw-back of funds from the ESFA

Underestimating the costs of administering the provision and contract.

Higher administration costs Pressure on budget

Further sub-contracting without the written approval of the ESFA.

Lack of due diligence checks to establish QPP’s other relationships

Poor quality of delivery, fail audit

and possible claw-back of funds

Competing for employer’s and students with other contracted provision

Poor communication over target markets, duplication of provision

Under-achievement of student targets, loss of reputation with employer’s

Failing to complete students and contract terminating, leaving students on-programme

Insufficient tracking of

performance during contract

year

Impact on student achievement rates. Pressure on budget

Staff turnover of the QPP, impacting on their capability and capacity to deliver

Inadequate contract

management and performance

checks

Impact on student and employer Poor quality of delivery. Unsuccessful completion of qualification

Risks associated with health and safety, safeguarding or equality and diversity issues

Lack of communication on

reporting issues and concerns

Impact on student and employer

Audit & Data The ESFA have the right to audit all documentation in relation to the sub contracted provision. A satisfactory audit is essential to avoid loss of funding through claw back or termination of contracts. Qube Learning’s audit principles include:

An external audit partner (appointed by Qube) will conduct an annual audit sample with each QPP (where cohort size is sufficient to warrant) to ensure records are valid and credible

DSATS and BI Tools are used to test integrity of data submitted by the QPP


Controls to ensure no double funding include:

Gaining information on other prime contractors at due diligence stage

Regular (monthly) DSATS testing

Communicating with other Prime contractors the Partner Provider has current or existing relationships with

External Assurance on Qube Learning subcontracting controls For each academic year the ESFA require Qube Learning to obtain a report from an external auditor on our arrangements to manage and control our delivery subcontractors. This is specified in paragraph 188 from the 2019/2020 funding rules below. P188. You must obtain an annual report from an external auditor if the total apprenticeship contracts with your delivery subcontractors will exceed £100,000 in any one financial year. The report must provide assurance on the arrangements to manage and control your delivery subcontractors. The report must comply with any guidance issued by us. You must supply us with a certificate signed by the external auditor and an authorised signatory to confirm you have received a report that provides satisfactory assurance. We may ask you to provide a copy of the full report. Contingency Plan In order to meet Qube Learning’s duty of care requirements, set out by the ESFA, it holds the responsibility to ensure students are not put at a disadvantage by any action of the QPP. If a QPP can no longer deliver the training, assessment and/or quality assurance of their provision, contingency plans have been developed. These ensure all students can make continuous progress, whilst alternative, suitable, arrangements are made If the failed provision is within the sectors of delivery that Qube Learning deliver, the contingency is to progress learners through our own resources, ensuring a continuation of learning. In some instances, provision may also be transferred to existing QPP’s that offer the provision. Where provision is outside of our capability, QPP staff CVs will be checked by our Talent Acquisition Partner to identify any individuals that could continue delivery on a freelance basis, should intervention be necessary. When assessing the suitability of a new partner, we undertake a risk assessment to determine our ability to deliver an effective contingency delivery plan. Summary Aside from the Associate Project Manager and Data Analyst Standards (due to their specialism), Qube Learning will no longer subcontract any end to end programme apprenticeship delivery. However, in some instances, Qube Learning may procure specialist services from RoATP approved providers to enhance the overall programme quality.

Documents

Working in Partnership - Qube Learning€¦ · POL0016 Working in Partnership V1 20191129 Quality Assurance Processes 70% Best Practice Sharing - Regular Updates Qube Learning aims