Supply Chain Fees and Charges Policy

1. Background


Newcastle City Learning is funded by the NTCA Adult Education Budget (AEB) to provide a range of learning programmes for learners aged 19+. Learning opportunities include accredited and vocational programmes leading to qualifications as well as non-accredited introductory and short programmes as part of Community Learning.
On occasion we may subcontract delivery where this meets our strategic aims and enhances the quality of our learning offer to meet the changing demands of the residents, employers and stakeholders of the city of Newcastle and surrounding areas.


2. Purpose of the policy


This policy is in place to ensure transparency and accountability in terms of supply chain activity carried out by Newcastle City Learning. 


3. Scope 


This policy applies to all sub-contracting activity that we enter into to deliver NTCA contracts. The policy will be amended for activity with any other funding bodies, such as the ESFA, if required.


4. Overarching principles


We will only use delivery subcontractors where:


•    We have the knowledge, skills, and experience within our organisation to successfully procure, contract with and manage those subcontractors
•    Where our Advisory Board/Governing Body and appropriate Council personnel determine the subcontractor to be of high quality and low risk
•    Where we have robust procedures to ensure subcontracting does not lead to the inadvertent funding of extremist organisations
•    All subcontracted providers have a valid UKPRN number


5. Rationale for subcontracting


We will only consider and enter into subcontracting where it enhances the quality of our learning offer and there is a clear educational rationale. 


It must meet one or more of the following aims:


•    enhances the opportunities available to learners 
•    fills gaps in niche or expert provision, or provides better access to training facilities 
•    supports better geographical access for learners 
•    offers an entry point for disadvantaged groups 
•    consideration of the impact on individuals who share protected characteristics


We will not subcontract to meet short-term funding objectives, or subcontract to a second level.


6. Selection and procurement


We will obtain written approval from the NTCA before awarding a contract to a subcontractor.
We will avoid conflicts of interest (actual or perceived) in the appointment of subcontractors.
We will make sure that learners supported through subcontracting arrangements know about our and our delivery subcontractor’s roles and responsibilities in providing the learning. 
Contracts will be awarded in line with Newcastle City Council’s Commissioning and Procurement Procedure Rules, and any procurement will be clear and transparent with due diligence checks carried out prior to appointment.


7. Terms we will include in our contracts with delivery subcontractors


We will make sure delivery subcontractors:


• meet the requirements set out in the NTCA funding rules
• provide us with ILR data so our data returns to the NTCA accurately reflect our subcontractor’s delivery information
• give the NTCA, and any other person nominated by them, access to their premises and all documents relating to the NTCA AEB funded provision
• always have suitably qualified staff available to provide the education and training the NTCA fund through the AEB
• co-operate with us to make sure there is continuity of learning if the subcontract ends for any reason
• tell us if evidence of any irregular financial or delivery activity arises


8. Ensuring the quality of education, teaching learning and assessment


The performance and quality of subcontracted activity will be monitored and managed through a range of processes and procedures including:


• Lesson visits, meetings, and conversations with learners. Reviewers may request evidence to carry out Case Studies as part of a wider deep dive quality assurance process. 
• A schedule of quality assurance monitoring visits to providers’ premises which will include checks on whether learners exist, and are eligible, and involve direct review of initial advice and guidance records, initial and diagnostic assessment records, and curriculum plans.
• Contract Review meetings with owners and managers, online or face to face where appropriate, to measure performance and put in place actions for improvement when necessary
• Feedback from learners and staff


9. Publication of information relating to subcontractors


We will publish our subcontracting policy, including fees and charges, on our website at the start of each academic year and update this as required throughout the year. We will publish the actual levels of funding paid and retained for each delivery subcontractor.


10. Funding rates


For accredited programmes, the rates will be based on those published within the ESFA’s Find a Learning Aim database.
For non-accredited Community Learning, quotes for each programme will be assessed by NCL in terms of quality, guided learning hours, learner numbers and overall value for money. 


11. Subcontracting fees and charges


The funding retained by us will cover the costs of the services provided. These services, and the levels of funding being retained for them, will be communicated to all stakeholders, and clearly documented as part of a contract agreement. 
For 2020-21, we will charge a management fee of 20% for all subcontracted activities. The fees charged reflect the cost of the commissioning and procurement processes, managing and quality assuring the provision, providing management information services, providing support for improvement, and for the administration of the individual contracts. 
Other charges may be made for any additional support deemed necessary to ensure that the quality of teaching, learning and assessment is maintained at good levels, and the success rates of the provision meet the required standards. 


12. Payment arrangements


We will agree contracts and details of payment arrangements prior to the delivery of provision by subcontractors. Provider payments are aligned to the delivery of specific outputs within a defined timeframe and providers must show evidence of their delivery via timely submission of the required data and documentation outlined in the contractual requirements. 
All providers are required to submit specified ILR information to demonstrate enrolment, eligibility, completion, and achievement of all learners recruited.


13. Contingency planning


All learners who undertake education and training programmes with providers subcontracted by Newcastle City Learning remain our responsibility. 
In the event of the following situations, we will be responsible for making alternative arrangements for the delivery of education and training:


• NCL withdraws or terminates a subcontract arrangement, or
• A subcontractor withdraws from the arrangement, or
• A subcontractor goes into liquidation or administration
We will ensure that continuity of learning and minimum disruption to learners will be our priority.