Adele Lochman

Can a subcontractor also be the EPAO?


We have been asked by an employer-provider if we, as a subcontractor (one of 3) to them, can apply to be the End Point Assessment Organisation for the standard we are delivering part of (as a subcontractor). We are on the EPAO register for other standards and are aware of the requirements around conflict of interest and no staff involved in delivery can be involved in the EPA etc. I am struggling to understand in the subcontracting guidance if we are breaching any rules becoming an EPAO for the employer-provider if we are being subcontracted to? Any help would be greatly appreciated! 


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Kelly Knights

The closest example I’ve seen of this is with degree apprenticeships.

I’d say it wouldn’t be allowed but let me check the rules for you.

Is there a reason why the employer doesn’t want to use an existing EPAO?


Adele Lochman

Hi Kelly, thanks so much for coming back so quickly. 

This one is also a degree apprenticeship - Level 6. 

There is only one EPAO currently on the register and they have a good relationship with us so want us to get on the register.

Thanks for having a look into this! 

Helen Cuthbert

Hi Adele, are you the awarding organisation for the subcontracted provision? Eg does the degree come from the uni?

If it is integrated or integrated aligned then yes you would be able to be if its non integrated i would say no...

Happy to chat if you want separately :)

Adele Lochman

Hi Helen, 

That's a really good question re the awarding organisation. I'll check that - thanks! 

It's non-integrated currently so I was thinking along the same lines as you. Just can't find any exact wording in any of the guidance.