One positive we’ll take from coronavirus is that it forced us to be innovative

Students need support more than ever during the Covid-19 crisis, and rapidly finding new ways to reach and engage with them has been challenging and eye-opening, says Dave Hopley, director of student services at Stoke on Trent College

The college halls are almost empty, but it’s been a busy day in student support services. This morning we sent out our weekly e-vouchers to all our students in receipt of the vulnerable bursary fund payments, or free school meals, so they could access money for food. 

Our trained counsellors provided emotional support to students and their families via video call, instant messaging and telephone. Two of our peer mentors – trained students who support other students – hosted their twice-weekly Zoom wellbeing session while another prepared for their weekly online craft workshop. Our wellbeing warriors wrote their blog, offering tips on self-care, body positivity, managing anxiety and mindfulness.

Our admissions team responded to calls and emails from young people worried about exam results, reassuring them that they’ll still have a place at the college in September; and we hosted the first of ten virtual open event sessions running throughout the week. 

Our careers team supported worried members of the public as well as students, providing virtual careers advice on training, CV writing and job hunting to anyone who needs it. 

While our doors may be closed to all but our vulnerable students, the college is still very much open. However, Covid-19 forced us to become a virtual college overnight and making sure that our 10,000 students and 400 staff feel safe, supported and engaged in our community has been one of the biggest challenges we’ve faced. 

It’s been a steep learning curve as we adapt to working in this virtual world. We’ve had to upskill in new areas of digital technology in a short space of time. Some staff didn’t even have wi-fi in their homes until this year, yet now they’re using digital technology every day. 

This has been one of the positive impacts of Covid-19. We’ve pulled together to introduce things almost overnight which would have taken months or even years to implement. People haven’t been afraid to come up with new ideas and try them out, even if they may not work. We set up an online debating club which was a success, and we’ve now started a Ludo club. We’re running a weekly group throughout May for Ramadan and we’re launching “Mr Slotivator” sessions – fun workouts to keep students active. 

It can be overwhelming for staff as well as students as they’re adapting to new ways of working while juggling their own family responsibilities, so we’ve taken a proactive approach to their wellbeing. We’ve introduced a “my acts of self-care” initiative and virtual time-to-talk sessions. We all want to feel connected, even when we’re apart. 

Engaging with students was challenging at first. They may be more digitally capable but they are not used to working in this way. We started small and built things up, using various communications channels to promote services. Word got out, students enjoyed something and told their friends, interest grew, and feedback so far has been really positive.  

We’d all like to go back to normal soon but there are definitely positives we’ll take from this experience and our virtual college won’t disappear when the doors reopen. Some things have worked so well online and will continue to complement what we do face to face in the long term. For example, our wellbeing services have become much more accessible and the team has supported more than 200 students and their families online. We’ve had more nominations than ever for our student union elections because students have found it easier to submit their manifesto online.  

I’m proud of the student services teams, who are working really hard at home to complement what our academic staff are doing, making sure that not only do our students achieve, but that they’re safe and supported in this unprecedented time.

Observations from a disappointed independent training provider

It is a mistake for the ESFA to use the apprenticeship achievement rate to measure the quality of provision. Neil Davies explains the true context that should be considered

I understand a journalist’s need to create the eye-catching headline, otherwise their article may get overlooked. A link to an article dropped into my inbox last week and on opening it, I inwardly groaned. Off the webpage sprang: “Providers that failed to meet the minimum standard for apprenticeship achievement rates last year will be informed next week of the government’s ‘action to challenge this situation’.”

The article went on to quote from an FE Week webcast earlier that week in which the skills minister Gillian Keegan had expressed concern at historic “low-quality” apprenticeships delivery and said: “I was quite shocked at some of the lower quality delivery that happened in the first stages of the levy being introduced.”

I feel sure that I join many ITPs who are fed up with statements that malign all our efforts and achievements without, seemingly, having an understanding of the full picture – a picture created by government. I believe some context is important.

The minister links lower quality to the advent of the levy. Whether a fan or not, the source of funding is not related to quality of delivery. Quantum certainly will be. In recent funding band reviews, government has reduced initial funding allocations across many apprenticeships. So if the vast majority of employers are unable to make a cost contribution, what might give if funding is reduced?

The minister and the Education & Skills Funding Agency are using the apprenticeship achievement rate (QAR) as a measure of the quality of provision. I do not see the direct link.

ITPs have done an incredible job in taking the scant new standard descriptors and developing employer-specific training plans. Such radical change is going to take time to implement effectively as both ITPs and employers learn to adapt. Do we believe that all this effort and investment is recognised?

Government insisted that ITPs start delivery of the new standards even though, for many, there were no end-point assessment organisations (EPAOS) approved. ITPs had to design delivery programmes to meet employer needs without knowing what the final assessment criteria might be. Do we believe that this potential systemic mismatch has been considered before criticism is levelled?

New EPAOS had no experience of implementing theoretical processes, and an arbitrary 90 days was deemed an appropriate timescale for end-point assessment. How many ITPs, learners and employers have been impacted by the inability or incapacity of EPAOs to respond to the pipeline of completing apprentices?

How many ITPs suffer financially because the 90 days was not achieved? How many ITPs suffer financially because their programme, agreed with the employer, did not quite map to the EPA final-assessment criteria? This resulted in either the loss of the vital completion element or incurring unbudgeted costs to get learners through EPA, or both.

Without an exemption Level 2, English and Maths became a mandatory element of apprenticeships. I dare say there will be many a tale of ITPs doing their utmost to get a learner through their functional skills, incurring additional costs, losing the 20 per cent completion payment. We all know that, despite best efforts, some learners will not achieve. Is it a fair indicator of quality?

The ESFA QAR number itself is difficult to reconcile and it is too blunt a tool to be an indicator of quality. ITP performance is affected by factors completely outside their influence or control: left employer, changed job role, on maternity leave, sickness absence etc. The raw data is available, so would it not be fairer to be judged on a wider range of factors. Would not a percentage entering EPA gateway and then the percentage achieving be a more interesting measure?

Our organisation was significantly impacted by the lack of capacity in EPAOs, and despite best efforts, a material number of our achievers fell into the following year. Curiously, while writing this article, the expected ESFA letter has dropped into my inbox. Thankfully, no intended action, as they have accepted the reasons behind their number. In our submission, to demonstrate the blip, we were able to point to currently outstanding achievement numbers for this funding year. Symptomatic, but sadly no word of recognition or appreciation of the good work being done.

DfE relaxes traineeship rules

The Department for Education has relaxed its requirement for students on traineeship programmes to record 100 hours of work experience owing to the social distancing measures caused by the coronavirus pandemic.

Providers will be allowed to the mark the component as complete if the trainee has completed more than 70 placement hours and they are satisfied that the learner has “gained sufficient work skills”, the department said in a statement tonight.

Officials will also allow providers to extend the traineeship programme duration up to 12 months where the learner has “not completed their qualification and basic skills learning aims including employability, maths or English” or where the student has completed less than 70 planned work experience hours.

They can also extend the duration if the provider has “assessed the learner as needing further work placement hours to complete this element of their traineeship”.

The DfE said this flexibility is offered “on the basis that the trainee undertakes online or alternative distance learning to complete other non-work experience learning and/or alternative work experience learning part of the traineeship where online learning is possible”.

Any provider that has trainees with reduced work experience hours should “record this and retain it as evidence for audit purposes” and the trainee should “continue with other learning aims via alternative methods such as online learning in order to complete these elements of their traineeship”.

Providers will need to “demonstrate” how they have continued to support trainees to develop their work experience skills in the absence of a work placement in the learner file such as “developing content that aligns with apprenticeship provision to facilitate smooth transitions from traineeship to apprenticeship” and “developing matching processes for when students can go on placements again”.

The DfE said they have introduced these flexibilities as they want to “enable providers to continue to deliver where possible given traineeships will play an important part in re-engaging and supporting young people to get back into learning and work following the coronavirus outbreak”.

Mark Dawe, the chief executive of the Association of Employment and Learning Providers, said his organisation “very much welcomes the changes as they will help keep a critical programme alive”.

But, he added, to prevent “abuse” on the relaxation of the work experience requirements, DfE “must only apply while the lockdown remains for each sector”.

Dawe continued: “The extended programme duration is also a sensible decision. It’s essential that traineeships are in rude health to help deal with the surge in youth unemployment and they can form the foundation of a wider pre-employment programme in the coming months.”

This evening’s announcement went on to detail how to extend 16 to 19 study programmes and how to extend 19 to 24 adult education budget and 16 to 18 traineeships without 16 to 19 study programme funding.

Here’s what it says in full:

Extending 16 to 19 study programme traineeships

“Our funding guidance sets out that planned hours should not be changed after the qualifying period unless correcting an error or starting a new study programme in-year. However, we recognise that in the current circumstances some students may need more hours than originally planned in order to complete their traineeship programme.

Where learners need longer than originally planned to complete their traineeship programme, we expect, in most cases, stretching their existing planned hours over a longer duration should provide the flexibility providers need.

In exceptional circumstances, where a learner with part-time hours requires significant extra delivery, while they are unable to deliver work experience with an employer, providers can increase the planned hours. Providers should record where an increase of planned hours is required in the learner file and demonstrate the need for increased hours to ensure learners remain engaged. We may ask for this evidence through monitoring processes.

The planned end date must not under any circumstances be changed or extended within the ILR. Providers should continue to record the end date of the programme using ‘Learning Actual End Date’.

We expect providers to arrange alternative provision to cover the delivery that cannot take place. The alternative delivery needs to be above the already planned work experience hours as these cannot be funded again within the same time period.

This is a temporary measure that applies only in this period of social distancing and while students are not able to access work placement activity.”

 

Extending 19 to 24 adult education budget and 16 to 18 traineeships without 16 to 19 study programme funding

“Where learners need longer than originally planned to complete their traineeship, programme providers should stretch their existing planned learning aims over a longer duration.

The planned end date must not under any circumstances be changed or extended within the ILR. Providers should continue to record the end date of the programme using ‘Learning Actual End Date’.

Additional funding demand in 2020 to 2021, as a result of the programme’s actual end date extending from the original planned end date in 2019 to 2020, may impact on the availability of growth in 2020 to 2021 if there is not sufficient budget available to support demand. It is your responsibility to ensure you meet the cost of trainees that continue into the following year within your funding year allocation.

This is a temporary measure that applies only in this period of social distancing and while students are not able to access work placement activity.

For more information, we are publishing a traineeship addendum to the ESFA adult education budget funding rules 2019 to 2020 on 13 May.”

Speed read: Highlights from our webinar with Toby Perkins

FE Week was joined by Labour’s shadow minister for apprenticeships and lifelong learning Toby Perkins on Monday for our latest webinar on the response to the coronavirus pandemic for the FE and skills sector.

Here were the main takeaway points.

Extend supplier relief support to levy-funded apprenticeships

The Labour Party believes the Education & Skills Funding Agency should extend its Covid-19 supplier relief to all apprenticeships, including those funded through the digital services that are currently barred from the financial support.

Perkins said the issue, which the Association of Employment and Learning Providers is challenging legally, needs to be implemented to “safeguard a tremendous amount of the sector”.

“I think it’s a position the government will ultimately be forced into, and the sooner they get on with it, the greater the reduction in casualties, either in terms of businesses and apprenticeships or in terms of job losses.”

 

A national skills response to coronavirus is needed

The shadow minister said it was important to attempt to predict the impact of the crisis on the economy and what the skills response to that should be. “I think that means there’s going to be a huge need for retraining.”

He claimed there are likely to be many people in the job market as a result, and proposes a major adult education and reskilling programme “to give people hope… To give people the skills that they need to adapt to the changing circumstances is absolutely crucial”.

Perkins went on to say he thinks the government needs to be giving “really serious thought to working collectively with the sector on the provision of all the alternatives that will enable us to build in a better-skilled future out of the current crisis”.

 

Colleges need additional funding for an expected increase in students

Perkins warned that if, due to the economic circumstances and furloughing of staff members, many companies decide not to go ahead with planned apprenticeships, colleges will be faced with a “massive increase in the number of full-time students”.

He is calling on the government to look at how colleges can be funded in the event they do find a surge in such learner numbers “to be able to provide that provision without hitting a cashflow crisis”.

 

Updating IT infrastructure would be ‘very valuable’

In response to Andrew Adonis’s controversial comments about education establishments not providing adequate online learning and support, Perkins said: “I think we all recognise that this is an incredibly difficult period of time and I think it’s important alongside any critiques to recognise the absolutely extraordinary steps that many teachers and lecturers are going to in order to provide both educational support and personal support to learners and to their families at this time.” He acknowledged that many in the sector were “dismayed” by Adonis’s comments, but added that Adonis may have heard alternative cases that have led him to believe that learners are being let down. If this is the case, these should be investigated.

The MP added there should be an assessment of what infrastructure is available to deliver remote learning. “I think there is always going to be a need to make sure you are investing in something that you are going to be able to continue to use going forward.”

He noted that there is representation to suggest that updating IT in the sector is “an overdue project anyway”, which would have both an immediate benefit plus longer-term benefits, “so I would absolutely support that.”

 

T-levels introduction may consume departmental attention

Last month the government said it is still committed to rolling out the first T-levels in September 2020, despite the pandemic. Perkins said his “biggest worry” with the plan is that the new qualifications are something that are going to affect a “tiny number of students in the first instance, but will consume a huge amount of departmental attention” and their ability to deal with “really pressing issues facing a far greater section of the sector”.

He admitted it is difficult to determine the impact from the outside but that, so long as they are in a position to address the other challenges, “I’ve no objection”.

Perkins added the other main obstacle with T-levels is the work-experience element. “That will be a substantial undertaking, I think, under any circumstances. To do it in the current climate is even more challenging, so there needs to be some flexibility around that sort of issue.

 

‘Huge concern’ over redundancies in the sector

Perkins said he is “very worried” about likely job losses in FE “on the back of nine or ten years of terrible economic allocation”. He is concerned that “if they were to see the sort of scale of cuts or deductions in income that I’m hearing, that there isn’t going to be enough in the system for them in some cases to even survive, but certainly to prevent really significant job losses in a sector that I just don’t feel can afford it”.

The shadow minister added that it must be ensured that the FE sector comes out of the crisis in a position to contribute to skills being at the “forefront of the national response” and with a workforce capable of achieving this.

Low Pay Commission calls on government to better protect apprentices

The government has been urged to take action against recurrent “very high levels” of illegally low apprentice wages.

The Low Pay Commission published its third report today to advise government on compliance with national minimum wage rates, and highlighted that as many as one in three apprentices in some age groups are not paid their entitlement.

The analysis suggests that “confusion” around the requirement to pay apprentices for their training hours is “likely to account for a large proportion of this underpayment”.

The report said the highest levels of non-compliance are recorded for apprentices aged 19 and over in their second year, which is after their minimum wage has increased from the apprentice rate to the appropriate minimum wage for their age.

“Large proportions” of younger, 16 to 18 year old apprentices in their first year, also report underpayment, it added.

The LPC has made a three recommendations to government to better protect apprentice wages.

These including using “targeted communications” to both apprentices and their employers to “highlight underpayment risks, and in particular the problem of non-payment of training hours”.

The second proposal is for HMRC to “review the way they record apprentice underpayment, and to publish the numbers and profile of the apprentices they identify as underpaid”, while the third is for the tax office to “review their approach to investigations involving apprentices, to understand whether these investigations would identify non-payment of training hours”.

The current apprentice rate, from 1 April 2020, is £4.15 per hour, which increases to the national minimum wage for over 19s when they move into their second year of the programme.

The LPC’s report uses the Apprenticeship Pay Survey (APS) as the most reliable source of minimum wage compliance. The latest survey, for 2019, was released in January and revealed a 1 per cent rise in illegal wages for apprentices.

It found that 19 per cent had reported being underpaid – slight increase on the 18 per cent rate from the last survey in 2017.

Non-compliance at levels 2 and 3 was higher than average in hairdressing, 48 per cent, and lowest on management apprenticeships, seven per cent.

Apprentices in England have to spend 20 per cent of their time training off-the-job, in line with Department for Education rules, which must be paid for by the employer.

The apprenticeship pay survey asks apprentices whose payslips show an hourly rate what that rate is and found that underpayment “according to this measure is significantly lower than when looking at the derived hourly rate,” according to the LBC.

“There tends to be a difference between stated and derived hourly pay across the pay distribution; this is more common at the lower end of the distribution, but is not restricted to apprentices whose pay is non-compliant.

“This suggests that the underpayment APS is finding is not simply a matter of employers paying the wrong rate, but rather of paying the right rate but for too few hours, and that this practice is widespread.”

The LBC said apprentices are also often underpaid if, for apprentices aged 19 and over, an employer fails to take account of the required NMW uplift at the end of the first year of an apprenticeship.

“HMRC have told us that this is often a factor in cases where they have found underpaid apprentices,” the report added.

“The year two increase in the minimum wage is clearly linked to higher underpayment among second-year apprentices –the groups subject to the uplift have the highest levels of underpayment.”

The LBC said it “often hears from stakeholders” that the apprentice rate is “more complex” than other national minimum wage rates, while other employers are “unaware” of the rules.

A government spokesperson said: “Everyone who is entitled to the National Minimum Wage, including apprentices, should receive it. All businesses, irrespective of size or sector, must pay the correct minimum wage to their staff, so we won’t hesitate to take action against those who fail to do so.

“That’s why we’ve more than doubled the budget for enforcement and compliance of the National Minimum Wage for this year, with HMRC having identified a record £24 million in unpaid wages for 220,000 workers in 2018/19.”

They added: “The government welcomes to Low Pay Commission’s report and will respond to its recommendations in due course.”

ESFA delays full rollout of digital apprenticeship system to April 2021

The full transition onto the digital apprenticeship system has been delayed by four months, the Education and Skills Funding Agency announced today.

Officials had planned to end provider funding allocations being used to train apprentices with small non-levy paying businesses by 31 October, with all starts to be managed through the online service from 1 November.

But “in light of the challenges being faced by providers and employers as a result of the current coronavirus pandemic” the transition period has been extended to 1 April 2021, the agency said in an update today.

“We are extending the transition period onto the service – funds available for new starts on non-levy procured contracts can now be used until 31 March 2021,” they added.

“We remain committed to giving smaller employers greater control over their apprenticeship choices by moving towards a system in which employers select an apprenticeship standard, choose their training provider and secure access to funding for all new apprenticeships through the apprenticeship service.

“As originally planned, this means, over time, more employers who do not pay the apprenticeship levy will begin to access apprenticeship training via the apprenticeship service, as well as through a provider with an existing government contract (now extended until 31 March 2021).

“Contract variations will be issued in the summer to support the changes and performance management rules will be confirmed shortly through the usual routes.”

Only larger employers with an annual pay bill of over £3 million who pay the apprenticeship levy can draw down funding for an unlimited number of starts from the online service.

Small employers were originally expected to have access to the service in April 2019. Their transition onto the system began in January but non-levy paying businesses have been capped initially and can only make reservations for up to three apprenticeship starts.

Today’s announcement comes amid a £10 million project to “simplify” the digital service, which is currently being tendered for by the ESFA.

Back to the drawing board for apprenticeship funding rate reform

The government’s apprenticeships quango has announced it will launch a second funding rate consultation – days before the deadline closes on the first consultation.

The Institute for Apprenticeships and Technical Education is currently seeking views on a proposed new model for setting individual apprenticeship standard funding rates, the deadline for which has been extended to 18 May owing to the disruption caused by Covid-19.

As FE Week reported at the time of the launch in February, funding rates for some apprenticeship standards could be cut by almost half under the plans.

Pilots of the new model were planned for this summer, but with that timeline now out the window, the institute said today it is going to use the additional time to consult on further changes.

“We are planning to incorporate feedback from the consultation on our funding model proposals into a more refined model,” a spokesperson said today.

“A second consultation will be launched on this.”

The institute is reforming apprenticeship funding rates following complaints from employers and providers that the existing system is not transparent enough.

They commissioned a report by IFF Research into the actual costs of delivering apprenticeships last year and used this to develop a new model.

An impact assessment was published alongside the consultation in February and detailed how significant rate reductions could result and made it clear the new method “strengthens value for money, by supporting employers to pay the appropriate costs for training and enabling more employers to access funding”.

The current consultation can be viewed here.

The IfATE is also currently consulting on a “simplified and strengthened” model of external quality assurance of apprenticeship assessments, which has a deadline of 21 May and can be viewed here.

Jennifer Coupland, chief executive of the institute, said: “It will be important that we give proper consideration to all the responses for both the funding and EQA consultations once they close and we will give a more detailed update on the next steps once we have had an opportunity to do that.”

Controversial closure plans to go ahead for college campus

A cash-strapped college group has confirmed it will close one of its rural campuses this summer in the face of local opposition.

Courses and the majority of the 122 staff working at RNN Group’s Dinnington site will be moved to other nearby campuses from September 2020.

Twenty-six staff remain at risk of losing their jobs, which is equivalent to 19 full-time jobs, while around 55 full time learners who were due to progress to the next academic year at the campus will have to be relocated.

The group wrote to Dinnington campus employees, students, parents and carers this week to inform them of the closure following consultation and advised “it will do everything it can to support them with the transition and move”.

Jason Austin, chief executive officer and principal, said: “We understand the strength of feeling for the Dinnington campus. However, we have had to take difficult decisions to ensure that the RNN Group is on a secure and sustainable financial footing and well positioned for the future.”

He added that, although the number of staff at risk was “significantly less than anticipated, any job losses are regrettable – especially during this challenging time with Covid-19”.

Earlier this year, at least 40 full-time jobs were expected to be lost.

“We are involved in early discussions about the future utilisation of the Dinnington buildings, which could potentially save some of the roles that remain at risk,” Austin continued.

Options being explored include renting or selling some or all of the buildings and land to help balance the books.

Conservative MP for Rother Valley, Alexander Stafford, previously told FE Week the move was previously deemed a “huge blow” to his constituency and “incredibly disappointing on so many levels”.

He met with FE Commissioner Richard Atkins in February to discuss the issue after RNN received a notice to improve from the Education and Skills Funding Agency due to Atkins’ “significant” concerns with the “quality and strength of governance oversight”.

The college group recorded a £4 million deficit in 2018/19 – almost double the shortfall it had the year before.

Affected students will either be relocated to Rotherham College’s town centre campus 10 miles away, North Notts College in Worksop seven miles away or Dearne Valley College in Wath-upon-Dearne which is 13 miles away from the start of the next academic year.

Stafford previously warned about the move’s effect on student and staff commutes as “public transport is atrocious and it will just really make them struggle”.

The Dinnington Campus is part of Rotherham College, which merged with merged with North Notts College in 2016 to form the RNN Group.

Curriculum currently offered at the Dinnington campus includes animal care and management, construction, countryside management and horticulture, foundation learning, health science, motor vehicle and access to higher education courses.

The decision to close the Dinnington Campus follows a wider review of the Group’s entire estate, which aims to release funding from the sale of land and property to re-invest in the development of some new curriculum and facilities at other campuses.

Approximately 575 learners have been studying 38 different courses at the campus this academic year, 480 of which were due to finish this summer.

The group is planning to provide more details on curriculum timetables and individual support plans regarding travel arrangements soon.

RNN is one of a number of colleges that have announced plans to close and sell off campuses and been met with MP opposition.

Other cases have included Cornwall College Group, BMet, Warrington & Vale Royal College and most recently Newton Rigg College.

AEB funding rules published in draft – but without threatened subcontracting limits

Draft rules for funding the adult education budget in 2020/21 have not included any changes to subcontracting despite the government’s warning of an overhaul.

The sector had been bracing itself for big amendments, including a funding and distance cap on the provision, following the Education and Skills Funding Agency’s ‘subcontracting post-16 education and training’ consultation, which closed on March 17.

The plan was to start implementing rule changes at the start of 2020/21 but none surfaced in the draft rules published today.

The ESFA said the rules are “our current advice for the funding year” and they “may publish further updates about the impact of Covid-19 on our funding rules as these become clear”.

The subcontracting consultation was launched earlier this year after the agency’s boss, Eileen Milner, sent a sector-wide letter warning she will take strong action against any provider that does not play by their rules, following scandals such as at Brooklands College.

When the call for views got underway in February, the ESFA said it was aiming to “eliminate subcontracting that is undertaken for purely financial reasons”.

Ten recommendations followed, including a percentage cap on provision of 25 per cent of a provider’s ESFA post-16 income in 2021/22, and further reducing that percentage to 17.5 per cent in 2022/23 and to 10 per cent in 2023/24.

It also proposed that where the aggregate value of a subcontractor’s delivery exceeds more than £3 million of ESFA funded provision, the agency would make a referral to Ofsted for the subcontractor to be subject to a direct inspection.

Another key recommendation was to introduce “stronger criteria for subcontracted provision delivered at a distance”, stating that as a “broad rule of thumb”, partners should be no more than one hour away from the prime contractor by car.

Further plans include stricter controls on the circumstances in which the whole of a learner’s programme can be subcontracted, as well as tighter oversight of sport related provision as it is a “particular concern” to the ESFA.

A new “rationale for subcontracting” requirement as part of provider subcontracting declarations is also in the works. Providers will need to “state the educational intent for entering into subcontracting arrangements and that governors and boards have agreed this”.

The consultation states that “entering into subcontracting arrangements for financial gain” will not be considered as an acceptable reason for doing so.

FE Week analysis of ESFA data shows that subcontracting accounted for £650 million in government funding for adults in 2018/19, and the practice fully or partially funded 25,230 students aged 16 to 19 at 587 subcontractors.