Sub-Contractor Management Policy

Interserve Learning and Employment (ILE)

ILE is committed to the delivery of a high quality Customer experience. This absolute objective is the main driver for all systems and processes and it is these processes that are designed to support operations in the meeting of contractual obligations and key performance indicators.

Our Mission

To deliver effective training and recruitment solutions for individuals and businesses, providing a positive economic impact across our communities.

Our Values

Bring better to life

We are all about believing we can do better. Asking questions, thinking differently, seeking solutions, and creating ideas to support our customers and add value.

Take pride in what you do

Whatever the task in hand, everybody can and should take pride in a job well done – a job undertaken with care, and done to the best of our abilities.

Everyone has a voice

Everyone has a voice, so we listen and encourage openness. We value all views and opinions, we welcome discussion and we treat people as we, ourselves, would want to be treated – with respect and patience.

Do the right thing

Doing the right thing means not accepting ‘that will do’, and not walking by when you could make a positive difference. The right thing also means the safe thing and the sustainable thing.

Aspiring to Supply Chain Excellent – Merlin Standard

Standards of performance are clearly defined and our approach to performance management is aligned to the principles of the Merlin Standard and Principles of Supply Chain Management.

Further information on Merlin Standards and Principles please visit www.merlinstandard.co.uk

Contract Management Framework (CFM)

The aim of this document is to outline Interserve Learning and Employments consistent standard for the management of all Supply Chain Partners across all contracts delivery.

Section 1 – Procurement

The Senior Management Team (SMT) and the Sub-Contractor management team must approve all applications to be a sub-contractor before a contract is issued. This forms part of our due diligence process. We have robust procedures in place to ensure that we only contract with organisations that are of a high quality and low risk. Through our tender and procurement process we ensure that we do not sub-contract with extremist organisations.

Our external auditors are required to assess our sub-contracting arrangements on a yearly basis to ensure they are of the highest standard. We also check any conflicts of interest and ensure providers are registered on the Register of Training Organisations (RTO) as required by our SFA contract. We check the list of Declared Subcontractors and RTO before appointing any sub-contractors. As part of our on-going review we make sure that any sub-contractor appointed continues to meet the RTO requirements.

Section 2 – Contracting / legal

Subcontractors comprise employers and other private training providers, all of which will have a formal signed Subcontractor Agreement. The agreement identifies volumes, regional delivery profiles, delivery targets, roles & responsibilities via a formal schedule(s) etc.

The Sub-contractor Management Team are responsible for ongoing contract management, including liaison with the Quality Team and Internal Audit team to ensure that periodic quality assurance and internal audit checks are undertaken.

Part of our contracting process requires our providers to regularly update us on any Ofsted Inspections they are involved in and the Grades awarded for their leadership and management.

We also check that any provision meets minimum standards for SFA contracting and SFA financial health assessments. We only award subcontracts for the delivery of funded provision to legal entities. If the legal entity is a registered company, it must be recorded as ‘active’ on the Companies House database. 

Section 3 – Contract Induction

The purpose of Contract Induction is to ensure that when a new SCP has been identified, they are provided with all of the information and assistance required to enable them to begin delivery on behalf of ILE and give them the best possible start to ensure success throughout the duration of the contract. We cover at this induction the roles and responsibilities of the subcontractor in providing learning activity on our behalf.

  • Introduction to ILE and its divisions
  • Walk through programme delivery model (if relevant)
  • Clarify performance expectations and monitoring timescales
  • Outline quality and compliance expectations
  • Deliver System and Paperwork training
  • Security requirements
  • Outline management fee services and support available  

At induction events and follow up meetings we ensure all subcontractors have a copy of and understand the funding rules for providing SFA provision. We have contingency plans in place if we need to withdraw from a subcontract arrangement for any reason.

Section 4 – Contract Management and Monitoring

Contract management aims are to apply a consistent and considered approach to the management of supply chain relationships. This is achieved through regular and systematic Monitoring of contract performance against Targets:-

Performance Reviews

Performance profiles are shared with Supply Chain Partners (SCP’s) before and post contract signing. These are subject to regular review during the life of the contract and are available on propriety management information systems. High levels of engagement between Contract Managers and SCP’s enable a proactive and active dialogue which leads to high performance and the delivery of key performance indicators.

The meetings schedule formalises the support available to each SCP in the delivery of contract requirements.

Frequency of Supply Chain Partner Activity:-

Performance Management – Remedial Action

Where performance is not at an acceptable level, a level of support will be agreed with the SCP. Performance will then be reviewed in the following quarter should the SCP fail to meet requirements at this time they will be deemed to be at Risk Band Level 1 of the Contract Management Framework.

Performance Improvement Level 1

Once a SCP has been identified as a level 1 underperformer, a formal letter will be sent highlighting this, and an invite to a meeting with our Regional Performance Manager/Operations Manager to discuss the matter further, using the following topics as agenda items:

  • Identify the causes of underperformance
  • Identify additional support that can be given to the Partner to improve performance
  • Agree improvement measures
  • Indicate the consequences of failing to reach the required performance levels
  • Set out the performance levels that must be reached over the next quarter

Complete PIP with agreed actions and timescales all details will be recorded and agreed between both parties. Interserve Learning and Employment will have the right to review, and if necessary, adjust profile targets, in line with business needs at that time.

Where a Partner achieves the indicated performance levels for the subsequent quarter the Partner will remain at Level 1.

Level 1 meetings will continue throughout these quarters or until low risk status is maintained.

Performance Improvement Level 2

Level 2 performance meetings will take place where Partners have failed to meet the performance levels indicated at level 1 within two 2 consecutive quarters. Performance will again be reviewed by the Contract Manager and the desired performance levels and timeframes will be indicated.

The consequences of continual underperformance will be discussed and we will inform the Partner that failure to meet the required standard may result in a formal notification of contract termination being issued in accordance with our contract terms and conditions.

Partners will be given have three months to implement any new improvement plans and achieve the indicated performance levels.

Where a Partner achieves the required performance level within three months they will remain at Level 2 status for the following two quarters or until low risk performance status is achieved.

Failure to achieve satisfactory performance improvement within the following three months may result in contract termination.

Call off Contracts

We recognise that certain elements of the CMF may not fully apply to any call off contractors due to the nature of their specific contract with ILE. We have therefore tailored our approach to contract management based on the key principles of any call off contract.

The contents of the CMF are all applicable; however the frequency and application may be adjusted to ensure that the call off contract is monitored effectively and appropriately.

Joint Communication Framework

ILE have developed a Joint communication framework following consultation with a selection of SCP’s across all contract areas. We are currently in the process of agreeing with our sub-contractors and partners the frequency and means of communications to be expected at all levels.

Quality and Assurance Framework

To ensure that our supply chain offer the best possible service to our customers, drive improvement initiatives and meet our contractual obligations, ILE will undertake rigorous scheduled audit activity. To ensure that this process is as transparent as possible, ILE processes include a comprehensive “self-audit” tool for SCP’s designed to use as part of their compliance requirements. ILE will moderate the results of partner self-audits to ensure a consistent standard is being met throughout the Supply Chain.

Compliance and quality are recognised as continuous processes, with an absolute imperative to drive the development of business processes that will assure the delivery of the required standards.

The Assurance Framework enables to prioritise actions and target resources where the risks are highest. All contracts will fall under scope of the Quality Assurance Framework within Self-checking, validated checking and independent evaluation during ‘on-site’ Quality Assurance Inspections together with provision of advice and guidance ensure contract compliance, high standard quality provision, identification of risk and solutions and the promotion of continuous improvement.

Much of the work of the Assurance Team will be routine assessment of the quality of customer documentation and experience, intervention records and evaluation of the effectiveness of processes, systems and controls in delivering business outcomes.

ILE has developed a tiered organisational structure through which a number of teams have been allocated responsibility for testing and monitoring contractual compliance.

The Assurance Manager reports to the Finance Director and is responsible for designing and delivering the Assurance Process, including review and evaluation and reporting to the Board and Risk Management Committee.

The Quality Manager reports to the Operations Director and has specific responsibilities for elements of the Assurance Framework including Self- Assessment, development and evaluation of teaching and learning tools and monitoring of delivery practice and Process and System training.

Our approach acknowledges that we cannot eliminate or control all risks but by developing the risk management methodologies currently used within the Organisation and incorporating structured risk management evaluations, we can create a robust control environment in which the business will flourish. For each contract an assurance checklist is developed and communicated to SCP’s. An annual schedule of inspections is maintained and feedback is provided at quarterly reviews.

For more information see the Quality Assurance Framework Claire.Copeland@interserve.com

Monitoring

ILE will be subjected to various monitoring activities by external bodies. These include but are not limited to the following:

  • Ofsted
  • European Social Funding (ESF)
  • Merlin
  • Matrix
  • Department for Work and Pensions (DWP)
  • Provider Assurance Team (PAT)

Part of ILE contractual requirements these external bodies are required to monitor and evaluate the entire supply chain within their remits. This may cover process checking, site visits, staff interviews and security compliance checks. Our SCP’s will be obliged to participate with any organisation that is undertaking compliance activities in connection to supply chain.

ILE will supply formal notification to its partners of any intended monitoring activities by external bodies.

Provider Assurance Management

ILE will be subjected to Provider Assurance Team monitoring undertaken by DWP. To ensure our partners meet the requirements of this process we will undertake a comprehensive Provide Assurance Management (PAM) process with our supply chain partners. You will be required to complete our Partner Assurance Monitoring document which allows Interserve Learning & Employment to evaluate your ability to meet the same high standards that will be expected by PAT. Partners will be notified when this document is required and given a timeframe for its completion.

Self-assessment Report (SAR) and Quality Improvement Planning

Self-assessment is pivotal to ability to improve quality and raise standards across its Provision.

ILE has a well-developed annual self-assessment and quality improvement planning process which uses an established grading system derived from the Common Inspection Framework to measure the effectiveness of performance

It gathers analyses and evaluates the results and outcomes of both operational and quality arrangements and underpins continuous quality improvement.

Central to self-assessment is the Customer. It is therefore crucial to evaluate and understand how effectively the Employment provision delivers a successful and high quality Customer experience.

  • Customer Forums
  • Best Practice Forums
  • Suggestion box
  • Customer Surveys

Areas identified through the Self – Assessment Reporting (SAR) process as requiring development are documented in a Quality Development Plan (Development); once agreed, this crucial document is systematically monitored to the point of resolution.

Supply chain Partners present progress towards completion of QIPs at monthly reviews, formally at Quarterly Reviews and additionally according to need, detailing:

  • Objectives/Detailed Actions
  • Person responsible for the specific action

Target Outcomes or Performance Indicator to evidence achievement

For clarification pertaining to Self-assessment, action plans please contact: jan.richardsonwilde@interserve.com

Security

The protection of any data that we process under our contract(s) is paramount. With this in mind ILE must ensure that we meet our own internal security requirements and those imposed upon us contractually and legislatively. We will carry out a rigorous due diligence process with all partners entering into agreements with us to ensure their compliance with these standards.

We will also perform continuous security compliance checks throughout the duration of any contract with all our partners within the supply chain. There will this be a requirement for you to submit a comprehensive security plan to our compliance department prior to contract commencement and review these at least annually. We will undertake physical compliance checks to provide assurance that your security plans are accurate, meet industry best practice and your organisation and staff have a full understanding of the security requirements of the contract.

Claims / Payment Process

Claims

The claims department at Warwick House produce a monthly schedule detailing all financial claims for the period. This is sent electronically to the sub-contractor three working days after the month end for them to reconcile and inform Interserve Learning & Employment of any variances within five working days. These are then reviewed and once agreed between both parties, a self-billing invoice will be raised.

Payments

All Self billing invoices will be paid within 30 days of the end of the month following the date of the self-billing invoice by BACS.

Policies and Procedures

All Policies are available on insite and the Partner’s extranet. All staff should read these Policies annually (or Partner’s approved equivalent versions) and where refresher training courses are a mandatory requirement, these should be undertaken at the specified frequency.

Compliance with these requirements will be tested by the Assurance Team during inspections, by questioning staff and following review of response to formal periodic requests for information.

Partner’s policies will be subjected to initial review during the Due Diligence checking process prior to contract award and annually thereafter.

  • Information Security
  • Whistleblowing
  • Health and Safety
  • Sustainable Development
  • Equality and Diversity
  • Safeguarding

Pre- employment checks Inc. DBS

5. Exit Strategy

An exit strategy will be instigated if the contract is approaching expiry or notice is served by either party. The exit strategy will be unique to the delivery Partner as the following variables will be taken into account.

Dispute Resolution Process

Supply Chain Partner agreements are Commercial in Confidence and are agreed individually during contract negotiations. There may be occasions where disputes arise between ILE and supply chain partners. We have a clear escalation process to resolve such incidents. In the first instance partner disputes will be investigated by our Regional Performance Manager. They should be notified in writing as soon as practically possible to instigate the investigation process. Should a satisfactory outcome not be reached then the dispute would be escalated to our Operations Director. Where resolution can still not be achieved the dispute would then be escalated to our Managing Director.

6. Subcontractor Revenues and Management Fees

Subcontractor Revenues and Management Fees

Supply Chain Fees and Charges Policy