Subcontracting Saved!
It's great news that subcontracting has been saved for the time being at least.
Now the wait is over we can see just what’s in store for subcontractors from May 2017.
"We appreciate that maintaining the ability to subcontract will, at least for a transitional period, be important for employers and providers."
FE Week published an article on the reversal of government plans to reduce subcontracting which highlights the power of the consultation period.
"At the employer’s request, and subject to their agreement, main providers will be able to bring in sub- contractors to deliver whole, or parts of, frameworks or standards."
Nick Linford mentioned this in his webinar yesterday that the SFA are still undecided about whether organisations who are not on the RoATP will be able to continue with their carry over apprenticeships from May 2017.
I will of course make sure I let you know the decision once it's known.
Important Notes for Subcontractors
The Apprenticeship funding: draft rules for training providers document covers subcontracting rules which include:
"You must only use delivery subcontractors that satisfy one of the following three criteria.
- 135.1. They are on the published Register of Apprenticeship Training Providers and have applied via the main or supporting application routes.
- 135.2. They are the apprentice’s employer or a connected company as defined by HMRC and are on the published Register of Apprenticeship Training Providers, having applied through the employer-provider application route.
- 135.3. They are not on the published Register of Apprenticeship Training Providers but will deliver less than £100,000 of apprenticeship training and on-programme assessment under contract across all main providers and employer-providers between 1 May 2017 and 31 March 2018." (Page 27)
I must admit that I find point 141 a little concerning, especially as most subcontractors have spent years developing and maintaining relationships with employers.
"141. You must maintain the relationship with each employer at all times. You must not allow a delivery subcontractor to lead that relationship." (Page 28)
Timetable
"* Please note that we use the dates for feedback and publication as a guide only. The exact dates will depend on the volume of applications that we receive."
Before You Apply to the RoATP
Well, according to the documentation there are a few essential things that must be in place or you will fail the application process.
• Registration with the Information Commissioner’s Office - (legal requirement).
• Registration with the UK Register of Learning Providers
• Policies / strategies in place to safeguard apprentices and careful attention to prevent duty.
• Equality and diversity policies and be able to tackle bullying and discrimination.
• Your organisation must have the expertise and experience to deliver effective and successful apprenticeships.
• You must be financially sound. Check out the financial health self-assessment toolkit.
Which Application Route?
Now all the documentation is published and the Register of Apprenticeship Training Providers is open, it's time to decide which application route to take.
The Joining the register of apprenticeship training providers – application instructions document gives details on the process and the Register of Apprenticeship Training Providers policy document provides final details of the rules.
1. The Main route
2. Employer provider route
3. Supporting route
You can only apply via one route and only complete one pre-qualification questionnaire (PQQ)
• PQQ 28910: Main route - register of apprenticeship training providers
• PQQ 28911: Employer provider route - register of apprenticeship training providers
• PQQ 28912: Supporting route - register of apprenticeship training providers
There is a guidance document available to help you through the process.
If you apply via the main route you must also tender to deliver apprenticeships to non levy employers, ITT 30190 on the e-tendering portal, the SFA will allocate an amount if successful.
A reminder: Only successful main route applicants to RoATP will be searchable by employers on the digital apprenticeship service.
Application Route
New Guidance Documents
There has been a whole host of documents released this week, I have attempted to list them here as some are a bit tricky to find.
The following are links to the updated SFA pages:
The Apprenticeship funding and performance management rules 2017 to 2018
Apprenticeship funding: how it will work
Apprenticeship funding from May 2017
Apprenticeship funding: how it will work
Here are the documents if you want to do a direct download:
Apprenticeship funding: rules and guidance for levy-paying employers
Apprenticeship funding: draft rules for employer-providers
Apprenticeship funding: draft rules for training providers
Draft apprenticeship performance management rules 2017 to 2018
Apprenticeship frameworks: funding bands from May 2017
Apprenticeship standards: funding bands from May 2017
Apprenticeship employer-provider guide
Apprenticeship funding in England from May 2017
The apprenticeship levy: how will employers respond?
Draft apprenticeship performance management rules 2017 to 2018
"Organisations applying through the main and employer provider routes must have a management information system in place at the point they begin delivery."
Page 10 Joining the register of apprenticeship training providers: application instructions
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