This document applies to all supply chain activity supported with funds supplied by the Department for Education (DFE) for apprenticeships. This document is a mandatory requirement that must be in place prior to participating in any sub-contracting activity. The content of this document has been developed in line with the DFE funding rules.
Lifetime Training Group (‘Lifetime’) will ensure that all provision funded through its direct DFE contracts, whether delivered by Lifetime or a sub-contracting organisation will provide an excellent learner experience and represent good use of public monies.
This policy provides transparency for all subcontractors, funding bodies and other associated parties or individuals regarding the procurement, due diligence process, support and charging rationale related to sub-contracted provision using Lifetime’s own direct contract.
This policy covers:
Rationale for sub-contracting
Procurement
Due Diligence Process
Contract Agreement
Management Fee Policy
Typical Management Calculations
Support Provided to sub-contractors
Contingency
Payment Terms
Communicating This Policy
Policy Review
Policy Amendments
Head of Audit and Risk
Finance Department
Chief Financial Officer
Quality & Curriculum - Overall responsibility for the quality improvement of sub-contracted provision, teaching practice and performance
Finance Department - Overall responsibility for contract negotiations/due diligence
Compliance and Audit – Funding assurance and compliance of learner records and data aligned to DfE contractual requirements
Lifetime utilises subcontractors to compliment apprenticeship delivery by providing expert training within the industry to support apprentices learning activities. Lifetime's subcontracting will:
Enhance the opportunities available for learners
Fill gaps in niche or expert provision
Provide access to high quality training facilities
Lifetime subcontracts only within apprenticeship provision and is intending to reduce subcontracted delivery where the expert provision can be delivered internally. Lifetime only subcontracts to organisations that are on the Apprenticeship Provider and Assessment Register (APAR). Where subcontracting applies, the subcontractor delivers part of the apprenticeship training to provide specific training to their employees as an employer provider or through workshop and expert training within programmes.
Delivery partners will only be contracted under a subcontract arrangement where Lifetime’s due diligence determines that the subcontractor has the capacity to deliver quality training which compliments Lifetime’s high-quality standards in line with all regulatory requirements including Ofsted and the ESFA.
The subcontractor delivers part of the apprenticeship training to provide specific training via workshop and expert training within programmes.
Procurement of subcontractor services will usually be in response to requests/approaches made by the potential contracting organisation to Lifetime. If additional procurement of sub-contracting services is required, this will be by invitation only and contracts shall be awarded based on an approached organisation’s suitability, track record and capacity to deliver the service.
Lifetime has a formal due diligence process as follows:
An initial discussion between a senior manager of the potential sub-contracting organisation and the Sub-contracting & Partnership Manager to ascertain provision type
Agreement to progress onto the due diligence stage confirmed by an Executive Team member
Issue of the due diligence document for completion by the potential sub-contractor
Receipt of the completed due diligence document and supporting evidence
Request for references made by Lifetime
Review of due diligence information (financial accounts) and members of the Quality team
A risk analysis conducted and documented collectively by the personnel above
Review of references obtained
A recommendation made to the executive team by contract managers and subcontracting stakeholders
A decision is agreed and confirmed by the Executive Team
Potential sub-contractor to be informed of decision
Lifetime will use the model subcontractor’s agreement published originally by the Education and Skills Funding Agency, amended as required by mutual agreement between both parties. As minimum content, this document includes all the mandatory requirements set out by the Department of Education (DFE) each year within the funding rules and regulations.
E) Management Fee Policy
Lifetime is committed to ensuring that the maximum amount of funding possible is passed on to our subcontractors to enable the best possible learning experience to the learner.
The percentage of funding retained by Lifetime is founded upon the basic requirement to cover the costs associated with the management of subcontracted provision along with an appropriate level of mark-up on such costs. The costs will vary according to the type of provision, the deemed risk of the provision and data processing/maintenance costs. These costs include but are not limited to the following considerations:
Direct costs of relevant personnel and their teams as detailed in section 3 ‘responsibilities’.
Pro-rata costs of any software licence costs resulting directly from the additional data-management required for sub-contracting activities.
Eligible and ineligible costs are determined by current DFE guidance.
Our published subcontracting activity and payments will detail the costs breakdown, showing the amount paid against the eligible costs. The cost breakdown will be in line with the funding rules against eligible and ineligible costs. Further detailed breakdown can be made available upon request.
The following support and facilities will be made available to Sub-contracting organisations at no additional charge to them:
Inclusion in CPD and other internal Lifetime programmes, as relevant and appropriate
Sharing of relevant information and publications/updates from the DFE and OFSTED made available to Lifetime
Advice and assistance as necessary in order for Sub-contractors to maintain a self-sufficient and effective ‘continuous improvement Strategy and associated working practices, including the Self-Assessment Process
Should a contract cease with any of Lifetimes’ subcontracts a contingency must be in place to ensure learners on programme are not disadvantaged in any way.
In this event, any learners on programme remain the responsibility of Lifetime Training as the lead provider and therefore, are responsible for finding alternative arrangements for the completion of their programme.
A subcontract contingency plan defines the options available in the occurrence of a termination of the contract in such situations as outlined in the plan.
The plan is intended to enable a quick and smooth transition for all learners involved to cause minimum disruption to their programme.
In both scenarios, Lifetime will appoint a senior manager to oversee the transition. This role will include liaising with all external stakeholders, learners, employers, DFE, awarding bodies and EPAO. They would also be responsible for ensuring Lifetime internal departments support the process, which includes compliance, quality, and finance.
The main scenarios to consider are:
Lead provider/subcontractor needs to withdraw from a subcontract agreement.
Subcontractor goes into liquidation or administration.
Full details of Lifetime’s contingency plan can be made available upon request.
Lifetime recognise the impact that cash flow has on smaller organisations and will always endeavour to ensure that payment for provision is made as soon as is practical after delivery has taken place.
Lifetime’s payment schedule is as follows:
| Event | Date/Deadline | Responsibility |
|---|---|---|
| Funding report released by DFE | 6th day of each month | Lifetime |
| Calculation of funds to be passed to subcontractor | 9th day of each month | Lifetime |
| Invoice supplied to Lifetime | 11th day of each month | Sub-contractor |
| BACS payment to Subcontractor | 12–15th day of each month | Lifetime |
This policy will be reviewed annually in June. Additional reviews and updates are completed as required.
We reserve the right to change the policy in particular instances where the policy is deemed to be unsuitable and without prior warning.
This version of the policy is effective from June 2025.