Support for LONDON O3 projects

Details of and supporting information for providers.

Supporting projects

To support providers in delivering their projects, a number of documents as well as relevant information will be made available in this section of the Web site.

Providers Manual – PAN 2

FAQ's

Assurance

A.1 Why do original records need to be held at the Lead Partner offices for the day of the assurance visit?

The lead partner has contractual obligation for record keeping for whole project / partnership and needs to put in place arrangements to best meet contractual obligations re: access and retention when the project has ended. Given that projects will need to have key documents at lead partner's premises at programme end, it makes sense to test this at the assurance visit.

If it would be more sensible, you could ask for the assurance visit to be held at a partner site, so long as original documents for all claims to date can be made available.

A. 2 Why do providers have to provide a list of OOM's vs beneficiaries' pre assurance visit?

You are asked to provide this at monitoring visits as well as prior to the assurance visit, in order to carry out testing of the evidence of your claims. PDM Tracker cannot be used to supply the detail of your claims, because there may be short records against which claims have not yet been made, as well as some claims which do not require you to update PDM.

Reconciliation of MMR and beneficiary data is also a good test of project management systems.

A.3 Do we get a chance to respond to Assurance reports?

Yes, the first report you receive is draft for comment. You will be asked to respond to any of the issues raised and explain how you will action any points for resolution.

A.4 Can we keep records electronically and destroy all the paper copies once the project has ended?

Electronic storage of documents is allowed providing that they are stored on a 'recognised data carrier', are certified as being copies of the original, meet with national standards and are auditable. In order to comply with these conditions:

(i) Documents must be on a commonly accepted data carrier, these include:

  • photocopies of original documents
  • microfiches of original documents
  • electronic versions of original documents on optical data carriers (such as CD-ROM, hard disk or magnetic disk)

(ii) Each document must be certified as conforming to the original document. The following declaration on headed paper will suffice as a minimum: 'I certify that this is a true copy of the original document (signed with date and position in organisation)'

(iii) Lead partners must keep the electronic copy of the document for the same duration as required for paper copies (i.e. 2018)

(iv) It is the lead partner's responsibility to ensure that the document can be relied upon for audit purposes

(v) It is the lead partner's responsibility to ensure the electronic copy can be retrieved for audit purposes

  • Further guidance on electronic storage of documents is available on www.esf.gov.uk .

Beneficiary Eligibility

B.1 Are staff from GP surgeries eligible for our project?

ESF cannot be used to support public sector GP or dental surgery staff, though staff in private GP or dental surgeries may be supported, if SME criteria and other individual eligibility criteria are satisfied.

B.2 Are self-employed beneficiaries eligible where the profile says "employed"?

In general, yes, provided they complete an "Employer Declaration Form", ticking the "self-employed" box. This should however be discussed with your Contract Manager. Where your specification states "employees of SMEs", self-employed individuals will not be eligible.

You cannot claim a self-employed person as an OP4 as well as an OP1 except in exceptional circumstances agreed during negotiation of your contract. Self-employed beneficiaries cannot confirm compliance with section 8 of the Asylum and Immigration Act 1996 (as came into force on 1 May 2004), applied to themselves, so will have to show other evidence of their right to work in the UK.

B.3 When I recruit employed beneficiaries do I have to check their passports?

In order for a beneficiary to be eligible you need to verify that they have the right to work in the UK. You can do this either by getting their employer to complete an Employer Declaration Form (available from the O3 website and which means you don't have to check their passports yourself) or by checking their right to work yourself which you can do either by checking their passport or one of the other combinations of documents listed in the Home Office guidance

http://www.ind.homeoffice.gov.uk/6353/18383/18469/shortguidance1.pdf

B.4 Is a beneficiary eligible if he/she has the stamp in their passport saying "No recourse to public funds"?

"No recourse to public funds" stamped on a beneficiary's documents is not a barrier to accessing an ESF-funded project, such as O3. Beneficiaries must still of course demonstrate that they are legally resident, and allowed to work in the UK. There may be additional restrictions stamped in the passport that you should look into.

B.5 Is a beneficiary who is unemployed, completes pre-employment training and who then progresses to employment with a non-SME eligible to undertake an accredited course under the project?

Yes as it is their status at the beginning as unemployed which makes them eligible. However the payment for progression to employment cannot be claimed until they have completely finished their course.

Beneficiary Evidence

C.1 Do beneficiaries have to sign records of attendance and how often are they required to sign?

Ideally beneficiaries should sign at each session, with the signature of the tutor on the same page to verify (see example attendance sheet). However it is acceptable for the tutor only to sign the attendance sheet, as long as they have actively checked and recorded this. Colleges may, for example, use electronic records that beneficiaries do not sign: tutors must in this instance sign to confirm records on a weekly/monthly basis.

C.2 Can we use our own version of a short record which has all the same boxes?

No - you must use the Pan London O3 Short Record form that you will find on our website and within PDM Tracker.

C.3 Can I claim beneficiaries where the evidence is at a partner site?

Technically you can, so long as that you are sure (i.e. have checked) that the evidence is in place (as we require you to do in the MMR). Basing your MMR on what evidence partners tell you they have in place (rather than also sending you a copy with their reported activity/financial claim) exposes you to considerable risk in that they may not be gathering all the evidence or may be gathering incorrect evidence. If you are operating this kind of system we recommend regular site visits to your partners to ensure that the evidence is in place. You need to bear in mind that an auditor will usually want to see original documentation.

C.4 Is there a template form for IAG sessions and should they be signed by the beneficiary?

This is individual and differs from project to project. This should reflect what was stated in your bid and the format should be agreed with your Contract Manager prior to use. The IAG form does not need to be signed by the beneficiary but if it is can be used as evidence of a timesheet.

C.5 How do we check postcodes are in the right LSC areas?

Use the postcode checker provided by Ecotec add (available from your Contract Manager), that gives the postcodes for all of the 5 LSC areas. Please note that the postcode database provided on the LSC website is not to be used as a checker for this programme.

SME / Employer Evidence & Eligibility

D.1 If we have an OP4 (SME engagement) in our profile, can we use the Employer Declaration Form instead of the SME form?

No, the OP4 evidence requirement is an SME form (together with a TNA form). Therefore it is better to complete the SME form, and then, if you want to use the Employer Declaration Form for the right to work evidence for employees, just use the front sheet as you need not duplicate the SME questions.

D.2 If we engage employed beneficiaries, do we need to use the Employer Declaration Form or the SME form?

The Employer Declaration Form is a requirement for employed beneficiaries: you must establish that the beneficiary is employed by an SME, and you may wish to ask the employer to declare that they have checked the beneficiary's right to work.

If you have asked the employer to complete an SME form already (for example, if you complete a TNA and claim for organisations engaged under OP4), you can omit the duplicated SME questions in the Employer Declaration Form - effectively using only the first sheet.

D.3 Are charities eligible as SME's?

Yes, providing all the SME criteria are met.

D.4 Is the trading arm of a large national charity classed as an SME if they have separate accounts to the main organisation.

This depends on a number of factors and separate accounts in itself does not determine whether an organisation is eligible as an SME. It depends on the relationship between the organisations. Guidance is contained in the New SME definition:

http://www.londono3.ecotec.co.uk/download/prog/SME_definition_report.pdf

D.6 Why does the Employer Declaration form need to be completed on the company's headed paper or with their logo?

The employer will make a declaration on the form that they have checked the beneficiaries' right to work in the UK. As this will be relied upon instead of direct evidence from the beneficiary such as their passport, the declaration needs to be in the form of an official company document.

D.7 What if they do not have letter headed paper?

Company stamp , VAT number or company registration number would suffice.

Other Evidence

E.1 Do I have to complete time sheets for staff that are employed full time on the project?

No. For staff working 100% on your Objective 3 PL2 project, you should keep job descriptions / employment contracts that clearly demonstrate that the relevant staff are working on the project full time.

E.2 Which forms are mandatory?

  • The SR form (unless you have a project without individual beneficiaries)
  • The SR Additional Aims form (where you have beneficiaries who undertake more than one learning aim)
  • The Economically Inactive form (if you enrol any beneficiaries who are economically inactive)
  • The SME registration form (where you engage SMEs, but not beneficiaries from those SMEs)
  • The Employer Declaration form (where you engage SMEs and enrol beneficiaries from them) – Please note this is to be printed on company letterhead.
  • Record of Evidence for Right to Work (where the Employer Declaration Form does not show that the employer has already checked this).

E.3 Can minutes of meetings be held online?

Yes, but they must be available for checking at monitoring visits

Beneficiary Support Costs

F.1 Can we claim for CRB checks under beneficiary support costs?

The wording of the evidence requirement for OP2 in your Delivery Profile should tell you what can be claimed. If CRB checks were included in the original calculation of beneficiary support costs in the budget you provided in your bid, this should have been included in your Delivery Profile.

If the CRB checks are a new cost you have identified, though, you will need to revise your budget, and you will need to fulfil the evidence requirement for OP2 as normal (receipt/invoice, signature of beneficiary to confirm receipt, plus beneficiary attendance record).

F.2 Can we claim for care of elderly/dependants under beneficiary support costs?

Yes, if this was included under beneficiary costs in the budget supplied in your bid. See above.

F.3 Do we need to keep receipts for OP2 claims where the invoice is paid direct to the carer?

Yes, all amounts claimed under OP2 have to be backed up by receipts regardless of whether the amount is reimbursed to the beneficiary or paid direct to a carer. This also applies where the project runs a créche specifically for project beneficiaries. In this case invoices must still be raised to each beneficiary supported by the service.

F.4 Can we claim the cost of materials e.g. tools under beneficiary support costs?

Beneficiary support costs should be specific to the individual, not the training. So for example, an electric drill would not be eligible, but a wheelchair ramp would.

F.5 Do childminders need to be registered?

Yes. Under the Children's Act 1989 a person who is paid to look after children under the age of eight other than in the child's own home and for more than two hours is a childminder and must be registered with Ofsted. Payments for childcare under this programme should be to registered childminders only.

F.6 Are ESF beneficiaries eligible for EMA?

No. However, projects are permitted to pay an allowance. If the beneficiary is in receipt of benefits, he/she may want to confirm with Job Centre Plus whether or not this allowance affects their benefit. This is responsibility of the beneficiary and not the provider.

Note that, if an allowance is to be paid, this must be clearly stated as a budget line in the finance section of your tender. Therefore, it will need to be agreed with your Contract Manager during contract negotiation, or will need to be approved as a significant change.

Short Records/PDM

G.1 What is the deadline for entering records on PDM?

Midnight between the second and third working days of the month – i.e. 12 hours prior to the noon deadline on the third working day for submitting the MMR.

 

G.2 Do we need to print off the short record from PDM once it is entered and get the beneficiary to sign it?

The short record needs to be entered online onto PDM and there must be a hard copy signed by the beneficiary. This can either be a print off from PDM which is then signed or the paper original which was used to enter onto PDM. There is no need to print the record from PDM simply as evidence that it has been entered as we can check the PDM reports for valid records.

G.3 Can additional aims be completed on PDM then printed off?

Yes.

 

G.4 When completing the prior attainment level on the short record, should we complete the highest level of qualification the beneficiary has ever achieved, or the highest level in the relevant subject/sector area?

You must enter the highest level achieved in general. The Highest level in that subject/sector area should be recorded in the ILP, and fulfil the criteria in appendix 2.

G.5 Are there fields on the short record which can be left blank?

Some fields on Section 2 of the SR can be left blank, if they are not relevant to your particular project, or to the beneficiary. These are:

 

Field Code

Description

If not relevant to:

A48a

Work placement postcode

Beneficiary (employed)

A48b

Employer location postcode

Beneficiary (not employed)

E20

Learner background

Beneficiary

E21

Support measures for learners with disabilities

Beneficiary

E16

Addressing gender stereotyping

Project or beneficiary (note that E16 should always be completed for projects under measure 5.1)

E19

Support measures to be accessed by the learner

Beneficiary

A46

National learning aim monitoring

Project

A49

Special projects and pilots

Project

L42

Provider specified learner data

Project or beneficiary (this field is optional, and can contain any data the project wishes to record)

G.6 How do we enter our milestone claims on PDM?

PDM is only for recording beneficiary details in relation to training undertaken, so you cannot enter anything for milestone claims. These should be claimed via your MMR once you state that you have all the required evidence in place.

G.7 Who is or isn't counted as a BME?

All ethnicity codes are counted as BME except 23 (White British), 24 (White Irish), 25 (White - Any Other Background) and 99 (Not Known/Not Provided).

G.8 What counts as a disability?

Section L14 of the Short Record Form asks you to input a code for Learning Difficulties/Disabilities.The conditions constituting a disability or learning difficulty are listed on page 43 of the LSC's ILR guidance.

http://www.lsc.gov.uk

G.9 What is my Dossier Number?

Dossier Numbers are automatically completed on PDM Tracker.

Dossier Numbers

Programme

Policy Field

Measure

Dossier Number

1

1

1

031025LN3

1

1

2

031026LN3

1

2

1

031027LN3

1

2

2

031028LN3

1

2

3

031029LN3

1

3

1

031030LN3

1

3

2

031031LN3

1

4

1

031032LN3

1

4

2

031033LN3

1

5

1

031034LN3

2

1

1

052024LN3

2

1

2

052025LN3

2

2

1

052026LN3

2

2

2

052027LN3

2

3

1

052028LN3

2

3

2

052029LN3

2

4

1

052030LN3

2

4

2

052031LN3

2

5

1

052032LN3

G.10 Can fields in the short record be pre-filled on the paper version and on PDM?

For PDM, no – because it is difficult to foresee what standardisation can be universally applied, and it is preferable for this to be checked for each beneficiary before entry. If you wish, you can pre-fill fields on the Word version of the SR on the O3 website to act as a prompt for partners where you expect standard data, but be careful not to cause them to overlook possible exceptions.

G.11 How many copies of short records should / need to be held on file for one beneficiary?

One SR (plus any additional aim forms).

G.12 Can the lead partner complete (sign) section 3 of Short Record on behalf of partners?

Yes, but whomever signs the SR needs to be confident that the details are correct, and there should be an audit trail to support this – e.g. date of completion and destination supplied by delivery partner by email.

G.13 If we have used the wrong short record and have subsequently completed a second one for each beneficiary, should the start date be the date the beneficiary signed the first or second short record?

The start date is the actual date of starting a course which should be entered on PDM and is when you are eligible to claim that beneficiary via your MMR. The date the beneficiary signs the short record can be an earlier date and if you have to complete a second short record they should put the actual date they signed the form, with the signature. The start date should still be the date of the start of the learning. Any variation of more than 8 weeks between the beneficiary signing the short record and starting the course should be explained using a file note attached to the short record, and the details on the short record verified with the beneficiary before starting the course to ensure they remain the same.

G.14 What date should be used for the Planned End date (E09)?

The date should be the date on which the beneficiary and tutor expect the activity leading to achievement of the learning aim to be complete.

The actual end date recorded in section 3 may be different to the planned end date. The planned end date relates only to the end of the learning aim, not the beneficiary's involvement in the project (which may continue through a further learning aim, for example, or support into employment).

G.15 Are economically inactive individuals a subset of unemployed individuals (E12 on Short Record)?

No, they are both subsets of worklessness, and have separate codes on the Short Record (04 for unemployed and 06 for economically inactive)

G.16 Does section 1 and section 2 of the SR have to be completed at the same time?

Not necessarily. You can use a different form (see the "Data Capture Form" on the O3 website) to gather the information from the beneficiary while they complete section 1 of the SR, then complete section 2 for them later. By the time you claim for their start, both sides of the SR must be complete.

The date of the beneficiary's signature should be no more than 12 weeks from the start date recorded on section 2.

G.17 What date should be used for the Date started ESF Co-financing (E08)?

The date of the start of the learning aim should be used: if this is XESF0001, this may include the date of the SR completion, otherwise, the date will normally be later: the start of significant learning activity, or IAG.

Monthly Monitoring Return

H.1 Can I claim Outputs & Outcomes before I put them on PDM Tracker?

No. Outputs and Outcomes can only be claimed in your MMR once the data has been input correctly into PDM Tracker and the evidence requirements stated in the delivery profile are in place.

H.2 What is the deadline for submitting the MMR?

Noon on the third working day of the month. Even if you submit an MMR with no errors at 12:15 on the third working day you will be asked to submit a nil claim for that month as we do not accept any MMRs after the deadline. This is because ECOTEC than has a very tight turn around time to aggregate information and send it to the LSC.

H.3 What is the cut off point in the month for responding to MMR queries to make sure we get paid that month?

In order to meet the deadline for payments on the 19th working day of the month, MMRs need to be finalised quickly where there are queries or issues to be resolved. Your MMR checker could set you a deadline that is less than two days away, if the deadline for the MMR to reach the finance department is imminent (usually a date between 15th and 20th).

H.4 What evidence do we have to send to ECOTEC to support our MMR claims?

The only time you have to submit evidence to ECOTEC in advance is to claim for MS1 (Partnership Agreement). For most other milestones you simply have to state on your MMR that you have the necessary evidence & for outputs and outcomes you can claim via the MMR once the correct information is completed on PDM and other evidence is in place. For impact assessments, evaluation and self assessment report these would be submitted at the point that they are completed and you want to claim them. Ecotec may periodically request you to submit other evidence between monitoring visits; in particular if an issue has been found during a monitoring visit we may request you to send copies of evidence prior to the next MMR submission. All evidence will be checked at monitoring visits.

H.5 How do we sign the MMR form when we are returning it by email?

Just leave this field blank, but complete Name, Position in Company, Organisation and Date and when you have submitted the final version of your MMR. print it off and sign where required. Keep this on file to be checked at the next monitoring visit.

Outcomes

I.1 Can beneficiaries do more than one OC3 or OC1?

Beneficiaries can complete more than one qualification however the lead provider will be paid only for the first OC1 and first OC3 per beneficiary, unless you have agreed otherwise with your contract manager and this is reflected in your Delivery Profile. Note that you will have standard wording in your delivery plan "Beneficiaries who achieve" unless you agree during contract negotiation that payments may be for multiple achievements.

I.2 Do part-time, seasonal or voluntary jobs count as progressions to employment?

Under the Pan London 2 programme, employment should be sustainable and include a support framework for the beneficiary for their first 3 to 6 months of work (programme prospectus, section 2). This means that seasonal jobs cannot count as progressions to employment. Part-time jobs can count as progressions to the employment so long as they are appropriate to the learner's level of ability, are sustainable and include a support framework for the beneficiary for their first 3 to 6 months of work.

Voluntary jobs do not count as progressions to employment, except by prior agreement during contract negotiations.

I.3 Where we have an OC4 outcome profiled as Apprenticeship starts, can we deliver the apprenticeship ourselves?

If it is funded outside of the project, and it meets the needs of the beneficiary, the OC4 can be delivered by one of the partner organisations. In order to meet need though, and allow beneficiaries maximum breadth, links should be made to as many other training providers as possible, to maximise success on OC4.

I.4 Can full time courses which are NOT delivered by Colleges count as a progression to full time education?

Yes, so long as the other criteria for a "full-time course" are met, and the qualification appears in the QCA's OpenQuals database of accredited qualifications and on the Learning Aims Database.

I.5 What length of course / how many hours qualifies as full time learning (in terms of a progression – OC4)?

A full-time, full year course would normally be 450 guided learning hours delivered in a year. Full-time study is normally considered to be a minimum of 16 guided learning hours per week.

I.6 Do our progressions into work have to be in the sector on which our project focuses?

For sector-specific specifications you are not required to prove that beneficiaries' new jobs are in your particular sector in order to claim for them, however you are expected to document your referral and support that helped them to find a job. You have been awarded the project on the basis of your links with one or more priority sectors - your training provision should be relevant to the sectors named in your bid, and progression routes set up within those sectors. You should review carefully any progressions by leavers into other sectors, therefore, to ensure that you supported the beneficiary appropriately and in line with your proposed sector-specific activity.

I.7 Do progressions into work and work placements have to be with SMEs rather than larger organisations?

No - ESF is used to benefit SMEs and certain individuals – as the benefit in these two instances is focussed on the individual, the SME criteria do not apply.

Partners

J.1 Can we add in extra partners?

You may submit a significant change request form, to provide a justification for such a change. This will need to include a description of the role that the partner is to play, replacing or supplementing existing partners' activities. If the change is accepted by your contract manager, you must update your partnership documentation, which your contract manager will subsequently ask to see.

J.2 Can we remove partners?

This constitutes a significant change, and you must think very carefully about how the original objectives, activities, pan-London impact and sectoral links will be preserved if you lose a partner. You will need to complete a significant change form; if the change is accepted then you will need to revise your partnership documentation as above. Where a partner has already undertaken some delivery, you should not remove them from your partnership agreement, but simply adjust the details of their role in the project.

When a partner withdraws, the lead partner should make arrangements for all auditable documents to be transferred to their premises, given that the lead will bear responsibility for any issues that may subsequently result in financial clawback.

J.3 Can we swap partners?

This will be handled as the loss and addition of a partner, through the significant change process.

J.4 Do Ecotec offer a Partner brokerage service?

No. Current providers are already in partnerships. You can consult the project descriptions to find out about partners, using the project search facility on the O3 website: http://www.londono3.ecotec.co.uk/projects/

Logos

K.1 Do minutes of steering group meetings need to have logos on and be signed?

No, internal documents, such as minutes do not need to have logos on. The minutes also do not need to be signed by the steering group, but the minutes of previous meetings should be minuted as agreed/approved at the next meeting.

K.2 Do we need to put logos on online assessment programmes?

This is not necessary where you are using an existing system, however where you are designing one for the purpose of the project then yes, it should have logos on.

K.3 Do we need to put the O3 logo on all our documents?

No, it is only the LSC logo and ESF logo which are compulsory, however the O3 logo also creates a unique identity for the project, so it is ideal if this logo can also be used according to the marketing /logo guidance (link below).

http://www.londono3.ecotec.co.uk/support/logos/

K.4 Is it ok if we also have other logos on our materials e.g. Job Centre Plus, LDA, Train to Gain?

Yes, as long as the ESF and LSC logos are still in the correct position, and that there is additional information given to beneficiaries to make it clear which project they are on, particularly where there is more than 1 project.

K.5 How do we access the LSC logo?

Via the LSC : Goka.Dela@lsc.gov.uk

Reports/Evaluation & Impact Assesments

L.1 What is required for the Self Assessment Report?

We advise you to consult the ALI website and contact Enfield College who are running the quality improvement capacity building contract under this programme for specific advice. Projects are required to follow the Common Inspection Framework, and apply the five questions of an ALI self-assessment to the project's training activity (including partners).

A broad template will be given to all projects who are not involved in the Capacity Building project, to follow in producing your SAR.

L.2 What is required for the Impact Assessments & Action Plans? How many pages? Will there be guidance or training?

Guidance was offered at the 23rd January provider event. Click on the icons below for the presentation, and a guidance note.

L.3 Can you provide a name of a good evaluator?

We do not recommend evaluators, but please see our new guidance note on Evaluation and contact any of the PL1 projects directly to hear their experience. Contact details and project descriptions here.

Other

M.1 What records have to be kept and who pays for the storage? / Can we keep scanned versions of documents? / Does the person who signed the contract have personal liability for the location / secure storage of all the documents?

This is an ESF / contractual requirement and original copies (or electronic scans) must be kept at the provider's cost for inspection at any time. Complete, accurate and valid records for all claims made must be kept in a logical filing system (including databases), with steps taken to prevent physical deterioration and ensure handover to successor organisation(s). The lead partner must pay for storage, which may be electronic (you may scan the documents). The organisation named in the contract has liability for the storage of the documents.

M.2 Do projects need to report all learner accidents to ECOTEC / LSC / Health and Safety Executive?

Only if the accident resulted in a visit to a Doctor / Hospital or more than 3 days off work. You should report the accident to Ecotec who will report it to the LSC, who in turn will report it to the HSE.

M.3 How do we access the contact details of other PL2 / ESF providers in London?

You can find contact details under the project descriptions, using the project search facility on the O3 website: http://www.londono3.ecotec.co.uk/projects/

You could also use the GOL directory, available at

http://www.go-london.gov.uk/european_structural_funds/objective_3/ESF_Projects_Directory

M.4 Do providers have to complete a Project Closure Report?

Ecotec will complete the Closure Report at programme level but all projects will need to complete a small addition to their final MMR, to include cumulative information on the narrative sections, a declaration that all activity is complete, and explanation of how records will be stored.

M.5 Can we reduce our targets or the amount paid for disabled, BME, Over 50's etc?

These targets will have been based on the figures you provided in your bid, which now forms Appendix 1 of your contract. Any reduction would be a significant change which would require strong justification and would need to be agreed with your Contract Manager.

Tools

Publicity and promotion

Sample forms

These sample beneficiary and staff monitoring forms are designed to help providers to develop their own monitoring documentation. These forms cover most of the information that providers need to provide for monitoring, record-keeping and audit purposes.

Email Bulletins

2007

2006

2005