Sub-contracting and Management Fees Policy

Purpose

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.

Our Commitment

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.

Objectives

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.

1. Scope
   This policy covers:   
   1. Rationale for sub-contracting
   2. Procurement
   3. Due Diligence Process
   4. Contract Agreement
   5. Management Fee Policy
   6. Typical Management Calculations
   7. Support Provided to sub-contractors
   8. Contingency
   9. Payment Terms
   10. Communicating This Policy
   11. Policy Review
   12. Policy Amendments
2.  Key Contacts
   • Head of Audit and Risk
   • Chief Learning Officer
   • Chief Financial Officer
3. Responsibilities
   • Quality & Curriculum - Overall responsibility for the quality improvement of sub-contracted provision, teaching practice and performance
   • CFO - Overall responsibility for contract negotiations/due diligence
   • Compliance and Audit – Funding assurance and compliance of learner records and data aligned to DfE contractual requirements

A) Rationale for Sub-Contracting

Lifetime utilises subcontractors to compliment apprenticeship delivery by providing expert training within the industry to support apprentices learning activities. Lifetime's subcontracting will:

1. Enhance the opportunities available for learners
2. Fill gaps in niche or expert provision
3. 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.

B) Procurement

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.

C) Due Diligence

Lifetime has a formal due diligence process as follows:

1. An initial discussion between a senior manager of the potential sub-contracting organisation and the Sub-contracting & Partnership Manager to ascertain provision type
2. Agreement to progress onto the due diligence stage confirmed by an Executive Team member
3. Issue of the due diligence document for completion by the potential sub-contractor
4. Receipt of the completed due diligence document and supporting evidence
5. Request for references made by Lifetime
6. Review of due diligence information (financial accounts) and members of the Quality team
7. A risk analysis conducted and documented collectively by the personnel above
8. Review of references obtained
9. A recommendation made to the executive team by contract managers and subcontracting stakeholders
10. A decision is agreed and confirmed by the Executive Team
11.   Potential sub-contractor to be informed of decision

D) Contract Agreement

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.

H) Contingency

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.

J) Communicating this Policy

This policy is published on the Lifetime website. Potential subcontracting organisations will be signposted to this policy prior to any contract agreement.

K) Policy Review

This policy will be reviewed annually in June. Additional reviews and updates are completed as required.

L) Policy Amendments

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 July 2026.