Author	Emma Lowe-Hewitt
Approval Body	Senior Leadership Team
Date of Approval	July 2023 – and reviewed annually
Date of Next Review	July 2027
Is this Policy included in the Staff Handbook?		No

Sub-contracting Policy 2026-2027

1. Introduction

1.1 Purpose

The purpose of this document is to give details of the Funding Policy offered by Rochdale Training to sub-contracted providers. This policy should be read in conjunction with other Rochdale Training policies and procedures and the sub contracting contract. The Policy applies solely to subcontracted provision funded through the Greater Manchester Combined Authority (GMCA) Adult Skills Fund (ASF) and Adult Skills Level 3 provision.Rochdale Training does not subcontract apprenticeship provision.

1.2 Publication

The Policy will be communicated to all sub-contracted providers prior to the sub contracting contract becoming operational. This policy will be revised annually in July as required by the DFE/GMCA Funding Rules. The policy will be accessible on Rochdale Training’s website no later than the 31st October annually.

1.3 Responsibility

Responsibility lies with the Senior Leadership Team to ensure that the Policy is reviewed annually and is adhered to.

1.4 Rationale

Rochdale Training is committed to delivering high-quality training to meet the skills needs of employers and learners within Greater Manchester and the surrounding areas in the Northwest.

Subcontracting will only be used where there is a clear strategic rationale, including extending provision to underserved communities, providing specialist or niche curriculum expertise, increasing engagement with priority learner groups, or meeting identified local and regional skills priorities within Greater Manchester. Rochdale Training will not subcontract purely to increase contract value or delivery volume

1.5 Due Diligence

Rochdale Training undertakes due diligence on all sub-contractors before final negotiations take place and a contract is issued to ensure we meet the GMCA funding rules.

We will review:

• Most recent Ofsted Report

• Relevant Policies and Procedures including Equality & Diversity, Safeguarding and Prevent

• Most recent Financial Accounts

• Most recent Self-Assessment Report

• DBS confirmation of the relevant staff

• Assessment of compliance with GMCA ASF Funding and Performance Management Rules 2026-27

• Review of subcontracting capability, governance arrangements and quality assurance systems

• Verification that appropriate data protection arrangements are in place

1.6 Contracting

Contract documents will require both parties to agree that supply chain achievements are attained through adherence to both the letter and the spirit of contracts or partnerships. Signatories therefore commit that all discussions, Sub-contracting Policy 2026-27 communications, negotiations, and actions undertaken to build, maintain and develop supply chains will be conducted in good faith.

We will only award contracts for delivering funded provision to legal entities. If the legal entity is a registered company, it must be recorded as ‘Active’ on the Companies House database.

A contract will only be issued after a successful outcome of due diligence. Subcontracting arrangements must support Rochdale Training's strategic objectives and comply with GMCA subcontracting requirements. Rochdale Training will normally deliver at least 60% of its GMCA-funded provision directly and will subcontract no more than 40% unless prior approval is obtained from GMCA.

Only one level of subcontracting is permitted. Subcontractors must not further subcontract any element of GMCA-funded delivery.

All sub-contractors must work in accordance with safeguarding policies and procedures and ensure that delivery staff are suitable to work with children and/or vulnerable adults.

1.7 We will not award a contract to a legal entity if:

▪ It has an above-average risk warning from a credit agency.

▪ It has passed a resolution (or the court has made an order) to wind up or liquidate the company, or administrators have been appointed, or

▪ Its statutory accounts are overdue.

Disclaimer: Rochdale Training reserves the right to amend its sub-contracting arrangements at any time in accordance with the terms and conditions contained in its standard contract for sub-contracted provision.

2. Fees 

Standard Fees

Management fees will normally not exceed 17.5% of the subcontract value unless exceptional circumstances apply and appropriate approval has been obtained. Fee retention will be transparent and will reflect the actual cost of managing, monitoring and supporting subcontracted delivery. The exact percentage will be confirmed in the sub contracting contract and is on an individual contract basis.

This percentage of the income will cover Rochdale Training’s costs relating to quality assurance, data management, contract oversight, contract monitoring, administrative tasks, etc.

The subcontractor will be responsible for all costs associated with programme delivery, including registration fees, certification fees, awarding organisation fees and any learner support costs not specifically agreed within the subcontract arrangement.

Standard Fee Plus Additional Support

Should the sub-contractor require additional support by Rochdale Training, dependent upon the circumstances, an additional amount will be retained by Rochdale Training. The exact amount will be discussed and agreed by both parties. An example of a sub-contractor requiring additional support could be a poor audit outcome and issues have been raised.

Payment Terms

Our standard payment term is 30 days from invoice date, subject to satisfactory validation checks.

3. Quality of Provision

Sub-contracted activity is part of Rochdale Training’s provision, and as such, the quality of provision will be monitored and managed through the existing Quality Assurance processes and procedures, which encompass all sub-contracted activity fully.

Rochdale Training will support sub-contracted provision by:

• Providing appropriate and well-experienced business support staff.

• Communicating regularly with Partners.

Plan and carry out performance, quality and compliance reviews at least quarterly to monitor enrolments, achievement, progression, learner outcomes, funding compliance and contract performance.

• Carrying out internal audit provision.

• Providing GMCA Adult Skills Fund funding rule updates, compliance guidance and performance management briefings, as required.

• Carrying out announced and unannounced visits to monitor IAG and Initial Assessment teaching, learning and assessment and appropriate use of DFE/GMCA funds.

• Providing update training on Equality & Diversity and Safeguarding/Prevent and sharing best practice, including teaching, learning and assessment workshops, as required.

• Collating, in partnership with sub-contracted provision feedback from learners and employers.

• Administering the programme payment schedule as agreed.

• Monitoring compliance with GMCA funding rules, learner eligibility requirements, evidence requirements and data returns.

Investigations of a sub-contractor will take place if the provider has been involved in any of the following and a Performance Improvement Notice (PIN) can be issued:

• Non-delivery of training

• Negative feedback, allegations or complaints received from learners, parents/carers, or employers

• Ofsted has awarded the provider an overall Grade 3 or 4 following inspection

• Failure to meet any performance criteria as detailed in the sub-contractor contract

• Sanctions are placed on the provider by an Awarding Body, relating to the delivery area(s) set out in the sub-contractor contract.

The provider is subject to significant regulatory intervention, contract suspension, insolvency proceedings, or serious funding compliance concerns.

Any financial irregularity, funding clawback, compliance breach or intervention by GMCA or other regulatory authority. Should Rochdale Training terminate a sub-contracting contract, we will work with the provider, learners, and employers to minimise the impact to them

4. Strategic Use of Subcontracting

Rochdale Training will only enter subcontracting arrangements where they add clear value to learners, employers and the Greater Manchester skills system.

Subcontracting arrangements will be used to:

• Extend access to ASF provision for underrepresented or hard-to-reach learners;

• Provide specialist or niche delivery not available internally;

• Support local priorities identified through Greater Manchester skills strategies;

• Increase progression opportunities for adult learners;

• Support targeted delivery where specialist expertise is required.

Rochdale Training will not subcontract for the primary purpose of increasing funded delivery volumes or income generation.

5. Disclaimer

Rochdale Training reserves the right to amend its subcontracting arrangements at any time in accordance with the requirements of funding rules and regulations.

Next Review: July 2027

Sub-contracting Funding Retained Policy 2025/2026 - Page 1 of 3