It is clear the SFA crackdown on subcontracting is increasingly pushing it underground.

Our findings this week on the rise of this hidden subcontracting have genuinely shocked me.

Some will try to claim ‘associate partnerships’ aren’t subcontracting because it is no different from using a recruitment agency to source a trainer.

This is nonsense, given the partner sources the learner, trainer and training facility.

It’s very clearly subcontracting in all but name, to avoid SFA bans for loans-funded provision and second-level subcontracting.

There is in fact a history of hiding subcontracting, if you go back a little over 15 years.

In 1999 the Further Education Funding Council called it ‘franchised’ provision.

Providers were found trying various partnership deals to claim it was still direct provision, and thus avoid the 1/3 automatic franchise funding discount.

In an important document at the time, FEFC circular 99/37, the funding body emphasised: “Partnership arrangements involving public funds should be transparent and available for scrutiny.”

If prompt action isn’t again taken, the SFA subcontracting bans and safeguards will be futile.

All ‘associate partnership’ deals need to be declared and should be classed as subcontracting.

No excuses and no hiding, for the sake of vulnerable learners and safeguarding public funds.