Assessment issues that may have an impact on your RTO audit (Part 1)

Category: Audits

Assessment issues that may have an impact on your RTO audit (Part 1)

Posted on by Sukh Sandhu

It is important to look into ASQAs 2017 report that shows:

  • Around 72% of RTOs FAIL audit on Assessment
  • Approximately 50% of those FAIL to be able to rectify their assessment tools on resubmission under the OLD audit mode

According to the new audit model:

  • There may be NO opportunity to rectify critical non-compliances
  • Initial registration clients with critical non-compliances are unlikely to get an opportunity to rectify and potentially would be unable to reapply
  • Registered RTOs risk sanctions, conditions, or even worse cancellations for critical non-compliances on the first audit

There are a number of assessment-related issues that may affect your audit outcome. You should ensure your assessment resources meet the following criteria:

  • Assessment resources have sufficient and clear information regarding what, when, how, where, why for your assessment template and all assessment tasks and activities.
  • Assessment resources have robust benchmarking and/or trainers guide.
  • Assessment resources are allowing the trainer/assessor to assess the skills and knowledge of students through different assessment tasks over a period of timeto ensure “consistency” and “sufficiency”
  • Each and every question and assessment task has very clear guidelines around what is expected from the students in terms of both “quantity” and “quality”
  • You have customised the off-the-shelf resources according to your RTO needs and requirements and not using them “as-it-is”
  • Your assessment resources are written by Industry experts with subject matter experts and are “Industry-relevant” and “current”
  • Your assessment resources address all requirements of the training packaging rules
  • Your assessment resources have detailed and valid performance checklists/observation checklists for assessing and observing the students before, during and after any skill assessment activity or workplace task
  • Your trainers and assessors gather sufficient, valid evidence for competency assessment
  • Your organisation offers appropriate simulated environments for conducting assessments
  • The authenticity of assessment, particularly in distance and online delivery is established and maintained

Various phases of the assessment and validation processes (Part 1)

Posted on by Sukh Sandhu

In this article, we will discuss different phases of validation processes that you should be following in your RTO to ensure you meet regulatory requirements and industry expectations.

Validation of RTO assessment resources

You must validate all your assessment resources to ensure they meet the principles of assessment, rules of evidence, training package requirements, regulatory guidelines and Industry expectations.

Explanation of assessment validation:

Validation is a process of checking that the assessment tools, methods, judgements, evidence and processes to ensure that the training product meets:

  • ​Principles of Assessment – i.e. valid, reliable, flexible and fair
  • Rules of Evidence – i.e. valid, authentic, current and sufficient
  • The judgment made by the trainer/assessor is benchmarked with colleagues or industry experts
  • There is sufficient evidence to support the judgment of the trainer/assessor
  • Whether the requirements of the Training Package or accredited course have been met.

Typical benchmarks used during the validation process include:

  • National training package which are developed by Skills Service Organisations (SSOs)/ Industry Reference Committees (IRCs) and can be found on the training.gov.au website.
  • Units of competency which consist of competency standards and need to be unpacked so that those validating the assessments can compare the actual competency against the tools being validated.
  • Industry standards and consultation will vary, and these standards form the basis of the skills and knowledge required to perform work roles.
  • AQF Guidelines and Framework
  • Information provided to candidates, assessors and third parties
  • Legislation relevant to the assessment such as privacy, health and safety, anti-discrimination, copyright law and so on.

Validation occurs through different stages:

Stage 1: Validation before assessment judgements i.e. pre-validation of assessment resources

Validation before assessment judgements are made; look at the design of the assessment activities, if it meets the training package requirements, how the instructions for tasks or questions are presented and the benchmarks against the learner performance. This is where the mapping is undertaken. You review the assessment tool templates in detail to ensure they are compliant and meet regulatory standards and Industry requirements.

Stage 2: Validation during assessment

Validation during assessment is looking at the actual benchmarking answers or performance the learner has provided, and making a judgement with another assessor, either together or separately. This often is coordinated within assessors who undertake training and assessment of the same vocational area. This process was also known as moderation and always remember prevention is always better than the cure, therefore, any issues identified at stage 1 or stage 2 should be eliminated as soon as possible and gaps should be filled with gap-analysis to ensure your organisation is bullet-proof.

The requirement in the Standards to undertake validation of assessment judgements (post validation) does not prohibit your RTO from undertaking moderation activities, or any other process aimed at increasing the quality of assessment.

Stage 3: Validation post assessment (i.e. post validation)

Validation post assessment concentrates on the learners’ performance and their responses to questions, the actual assessment decision that was made, the task and processes that align to the assessment, any feedback from students, and the reporting processes.

The purpose of this post-assessment validation is to verify the validity and consistency of assessment decisions to bring assessment judgements and standards into alignment.

It is a process that ensures the same standards are applied to all assessment results within the same Unit(s) of Competency. It is an active process in the sense that adjustments to assessor judgements are made to overcome differences in the difficulty of the tool and/or the severity of judgements. It aims to ensure assessors have a common understanding of the unit requirements

It involves checking that your assessment tools have produced valid, reliable, sufficient, current and authentic evidence, enabling RTO to make reasonable judgements that the training package requirements have been met.

(To be continued in the upcoming blogs)

Part 1- Contextualising of assessment resources 

Posted on by Sukh Sandhu

Contextualisation of training packages, accredited curricula and learning resources can be achieved without compromising the Standards for Registered Training Organisations (RTOs) 2015. Contextualisation is the addition of industry-specific information to tailor the Standards for Registered Training Organisations (RTOs) 2015 to reflect the immediate operating context and thereby increase its relevance for the learner. Contextualisation is ultimately defined as; the activity undertaken by a Trainer/Assessor to make units of competency, accredited curricula or learning resources meaningful to the learner.

WHAT is contextualisation?

Contextualisation means adjusting units of competency or packaging certain units of competency together to meet the needs of the enterprise or the learner. 

WHY is contextualisation so important?

Contextualisation gives VET providers the flexibility to create a meaningful program for learners whilst ensuring standards are met, and an accredited AQF qualification is obtainable. Contextualisation can make learning more realistic by providing real life and actual workplace examples. Contextualisation also accommodates specific industry needs.

WHAT are the rules for contextualisation?

Contextualisation must comply with the guidelines for contextualisation. Contextualisation must not change the unit of competency’s elements or performance criteria. It can only provide additional information to the range of assessment conditions and assessment requirements in a unit of competency. You must meet the requirements of foundation skills provided under the Australian Core Skills Framework (ACSF) which places mandatory facilitation and assessment compliance requirements associated with: Learning, Reading, Writing, Oral Communication, Numeracy and Digital Technology. 

It must not limit the breadth or portability of the unit/s.

HOW do you contextualise?

There are two ways in which contextualisation occurs:

  1. Delivery of units of competency to reflect a local need by providing additional options or contextualizing assessment to meet the needs of the learner group being assessed.

  2. Packaging units together using elective options to achieve particular outcomes

 

WHY do you need to contextualise assessments?

Contextualising assessment resources ensures that candidates are able to apply their skills and knowledge in a work setting and can be assessed as competent for a particular work context.

WHO is responsible for contextualising assessments?

Registered Training Organisations (RTOs) are responsible for:

  • identifying the target audience/ or client group for whom use of the assessment resources will be relevant
  • adapting and contextualising learning resources and, in particular, assessments, to address group and individual needs, relevant to industry and local conditions It is advisable that trainer/ assessors consider each assessment in the context of the specific industry sector and/or organisation and make adjustments or contextualise as necessary.

 

RTOs should contextualise in line with reasonable adjustment practices, ensuring that contextualisation will result in consistent assessment practices throughout the organisation.

Read more here…

Writing your Training and Assessment Strategy – Part 1 of Part 5

Posted on by Sukh Sandhu

A Training and Assessment Strategy (TAS) is the approach of, and method adopted by, an RTO with respect to training and assessment designed to enable learners to meet the requirements of the training package or accredited course (Glossary, Standards for RTOs 2015).

The Training and Assessment Strategy (TAS) is a high-level view of a program that guides the learning requirements and the teaching, training and assessment arrangements of a VET qualification. It is a “how-to” guide that defines and explains the process of developing, delivering and managing a training program. 

The Training and Assessment Strategy (TAS) is also called a Learning and Assessment Strategy (LAS), Qualification Delivery and Assessment Strategy (QDAS) or simply; a helicopter document. We strongly suggest you name your document according to the terminology and words mentioned within the Standards for Registered Training Organisations (RTOs) 2015. 

The Training and Assessment Strategy (TAS) is used to convey information such as;

  • The qualification (if applicable) or unit of competency training product codes and titles 
  • Requirements to enrol in the course (set by the RTO)
  • The core and elective units of competency in the course and a rationale 
  • Details of the training product and  alignment with the qualification packaging rules 
  • Prerequisites (pre-existing knowledge and skills) to enrol in the training product (as per the training package)
  • Details of the training organisation and contact person 
  • Any clustering (grouping) of units
  • The learner cohort/ training group (description of employment status, academic background, domestic or international, related industry experience)  
  • The mode and method of training delivery 
  • The mode and method of assessment
  • Entry and exit points 
  • Pathways to, from and employment 
  • Timeframes for delivery and assessment
  • Volume of learning and amount of training 
  • Information regarding work-placement requirements, if applicable 
  • Information how training and assessment is going to take place 
  • Details of staff qualified to deliver and assess the training
  • Equipment, facilities and resources required
  • Explanation and outline of  industry consultation 
  • Explanation and outline of how industry feedback has contributed to changes in training and assessment, facilities and resources, training and assessment skills of trainers and assessors 
  • How the program has been validated 
  • Sequence of delivery of units according to a priority order 
  • Review and approval processes for training and assessment strategies to both staff and regulators (in the case of nationally recognised training).  

This information is initially constructed to form an overarching strategy which will allow the training organisation to validate that it possesses the organisational capacity to deliver the qualification; giving thought to any specific venue, access to equipment as well as qualified staff; both from a vocational and training and assessment perspective.

The Training and Assessment Strategy, therefore,  outlines the macro-level requirements of the learning and assessment process. 

The Training and Assessment Strategy tool or template can be developed using a Word document (.docx). It is an active document and should be modified and updated to match what, where, when and how the training organisation is delivering a training product. 

How auditors use the training and assessment strategy 

The auditors make sure the strategy provides the framework to deliver a quality training product. Their main focus stays on: 

  • Where the training will be delivered 
  • How the training will be delivered   
  • What  the method of the course delivery is
  • What resources and/or support services are provided to the student 
  • Who is delivering the training and any skill-gaps 
  • How clear are entry and exit requirements 
  • How clear the instructions and information for trainers and assessors are when using the strategy 

The regulatory body can ask you to provide a compliant training and assessment strategy at any time before, during or after an audit or any regulatory activity such as at the time of addition to scope application etc. 

You must develop a training and assessment strategy before you start delivering training. The strategy should be validated to ensure it is “fit-for-purpose”. You need to develop training and assessment strategies when you are planning to deliver a course/training product. 

You must have a fit for purpose training assessment strategy for:   

  • each course and/or training product  
  • each delivery mode (class-room based, online, workplace delivery etc) 
  • each learner cohort 
  • each location 
  • or any other variation in teaching, learning, assessment and support arrangements 

Where any variations occur in training and assessment you must provide a modified TAS. A common situation occurs where a training and assessment strategy has been developed for one learner cohort, however the training organisation is asked to deliver to a very different cohort.  For example a TAS initially developed to deliver training to mature students with substantial industry experience with a shorter delivery time frame and assessment methods which utilise the candidates prior experience- or application to the workplace.  If the RTO’s new learner cohort has little to no experience, the TAS will not be fit for purpose. 

There is also no “single size” template for a TAS. All variations must be correctly recorded through a customised or new training and assessment strategy. The training organisation must consider: 

  • How the revised or updated training and assessment strategy provides a clear framework for delivering a quality training product or course 
  • Support needs and requirements to deliver a training product 
  • How the course delivery suits the learner cohort  or alternatively, referring to the opportunity to another provider if the cohort does not meet their business model.

In our next editions, we will discuss: 

  • What should be included in a training and assessment strategy (TAS) template 
  • How to complete a training and assessment strategy (TAS) template 
  • Review and manage training and assessment strategy (TAS) tool 

References: 

https://www.asqa.gov.au/standards/training-assessment/clauses-1.1-to-1.4-2.2

How to complete a compliant Trainer Matrix – Part 1 of Part 5

Posted on by Sukh Sandhu

We believe that representatives of the training organisations and trainers usually do not understand the importance of the correct and current trainer matrix available for audit. If you do not keep on top of compliance requirements, you may fall behind and you will not realise that your trainers can not actually train or assess the students they have been allocated.

In this article we have included some of the most important aspects needed for a compliant Trainer Matrix.

The Trainer Matrix

A Trainer Matrix (sometimes also called staff matrix, training matrix, training chart) is a tool that can be used to track the training and skill levels of a training staff member within an organisation.

A trainer matrix has a variety of uses such as:

  • It tracks the skills, knowledge and expertise required to train and assess a training product
  • It documents and compares the required competencies for a position with the current skill level of the employees performing the role
  • It allows organisations to assess how they can move forward with training programs and initiatives
  • It provides a gap analysis between required and actual knowledge levels
  • It tracks competency levels and supports the development of an action plan to reach the ideal staff skills level
  • It provides the information required for the development of a professional development plan and budget
  • It aids management with development planning by providing a framework of the teaching and training skills (current and future)

 

ASQA guidelines related to trainer and assessor requirements:

As part of the Standards, an RTO’s training and assessment may only be delivered by trainers and assessors who:

  • hold the required credentials (Standards 1.14 and 1.15, Schedule 1 of the Standards)
  • hold vocational competencies at least to the level being delivered and assessed (Standard 1.13[a])
  • have current industry skills directly relevant to the training and assessment being provided (Standard 1.13[b])
  • have current knowledge and skills in vocational training and learning that informs their training and assessment (Standard 1.13[c])
  • undertake relevant professional development (Standard 1.16).

Keeping evidence

Your RTO needs to retain sufficient evidence for each trainer and assessor to show that they can demonstrate appropriate competency, currency and professional development and the RTO must verify the information presented.

Verification may include:

  • contacting the provider named on a person’s evidence (including qualifications) to confirm that the documentation is genuine
  • conducting referee checks at the time of employment to confirm relevant industry experience.

You need to keep the evidence showing how you have verified this information. The best way to do this is in a compliant trainer matrix. The template of a trainer matrix can be prepared using a word-processing tool, spreadsheet or online management system.

In our next editions, we will discuss:

  • What should be included in the trainer matrix template
  • How to complete a trainer matrix template
  • Review and manage trainer matrix tool

References:

https://www.asqa.gov.au/resources/fact-sheets/meeting-trainer-and-assessor-requirements

Annual declaration on compliance

Posted on by Sukh Sandhu

Are you confident that your RTO meets current compliance requirements with RTO standards? Or do you need help?

All Australian Registered Training Organisations (RTOs) are required to submit an annual declaration on compliance with the RTO standards applicable to their organisation on or before 31st March 2018.

The CEO Declaration

The declaration is a legal document and the CEO must be truthful and completely open and transparent in making the declaration. The CEO is making the declaration to ensure that the RTO complies with all requirements of the VET Quality Framework as relevant to the training products on the RTO’s scope. There are a number of penalties under the National Vocational Education and Training Regulator Act 2011 that all CEOs should be aware of.

https://www.legislation.gov.au/Details/C2017C00245

Failure to submit this annual declaration is a breach of conditions of registration as an RTO.

Annual declaration requirements

An annual declaration confirms the CEO has systematically monitored the RTO’s compliance with the Standards and whether any issues identified they have been rectified or otherwise appropriately risk-managed. The declaration must be signed by the RTO’s Chief Executive Officer (CEO), who is responsible for the RTO’s operations.

The declaration requires the CEO to testify that:
all information about the RTO on training.gov.au is accurate (or, if it is inaccurate, that ASQA has been notified of necessary changes
to the best of the CEO’s knowledge, all owners and high managerial agents meet the Fit and Proper Person Requirements.

Demonstrating compliance includes, but is not limited to, showing how the RTO complies with (if applicable):

  • the NVR Act and the legislative instruments it enables
  • the VET Quality Framework
  • legislation, regulations and standards related to delivery of training to overseas students
  • VET Student Loans legislation and rules
  • workplace health and safety legislation and regulation
  • santi-discrimination legislation and regulations

consumer protection requirements

The CEO needs to ensure that the RTO currently complies with each national standard and if not, what actions are being taken to remedy non-compliance, especially but not limited to, the following compliance areas:

1. Training and assessment strategies

The RTO has a compliant Training and Assessment Strategy (TAS) for each course delivery type (such as online, classroom, workplace, distance, blended) and cohort of student (domestic, International).

2. Industry consultation

The RTO has conducted a ‘range of Industry consultations’ and systematically used the outcome of the Industry engagement to ensure the Industry relevance of the training and assessment strategies, practices and resources and current industry skills of the trainers and assessors.

3. Trainers and assessors

The RTO has sufficient trainers to deliver each training product on the scope. The trainers/assessors have demonstrated their vocational competency and Industry currency at each unit level and meet VET knowledge and currency requirements. The trainer and assessor files contain signed copies of their annually updated resumes, certified qualifications and skills matrixes.

4. Pre-enrolment information

Information, whether disseminated directly by the RTO or on its behalf, is both accurate and factual and provides students with sufficient information to make an informed decision to enrol in the course with your RTO.

5. Validation schedule

The RTO has implemented a plan for ongoing systematic validation of assessment practices and judgements for each training product on the RTO’s scope of registration including;
when assessment validation will occur;
which training products will be the focus of the validation;
who will lead and participate in validation activities;
how the outcomes of these activities will be documented and acted upon.
As per ASQA’s Standards for RTOs 2015, the RTO’s validation plan must ensure that:
All training product on the RTO’s scope of registration undergoes validation at least once every five years.
The RTO must validate at least 50 per cent of the training products in the first three years of the cycle.
You may need to validate certain training products more often where specific risks have been identified, for example, if your RTO’s industry consultation identifies areas of particular risk. ASQA may from time to time determine specific training products that must have particular attention paid to them and this advice is published to www.asqa.gov.au.
You can read more about validation schedule and conducting validation at https://www.caqa.com.au/validation-and-moderation-services.

6. Training and assessment materials

The RTO has sufficient, industry-relevant, compliant resources and materials to train and assess all training products on your RTO’s scope. The training and assessment materials meet the training package requirements and Industry expectations.

7. Language, literacy and numeracy and support requirements

The RTO can demonstrate how it identifies language, literacy, numeracy and learning requirements for each and every student in every course and how the RTO will provide adequate support for them.

8. Transition planning

The RTO has prepared a compliant transition plan to demonstrate that:
the commencement of a new learner in a training product which is no longer current (i.e. the training product has been superseded, removed or deleted from the National Register); and
the time-frame in which an RTO must complete the training, assessment and AQF certification documentation issuance for learners enrolled in a training product which is, or becomes, no longer current.

9. RTO Policies and Procedures, Forms and Manuals, Records management system and Practices

The RTO has compliant policies, procedures, forms, manuals, records management systems for effective retrieval, retention and protection of records, complaints management, regulatory compliance, minimising litigation risks, safeguarding important information, better management decision making, version control and RTO practices to ensure the organisation follow a compliant framework to maintain its registration with the regulatory bodies.

10. AVETMISS compliant database

The RTO has collected and reported ‘Total VET Activity’ data. This includes full Australian Vocational Education and Training Management Information Statistical Standard (AVETMISS) data, in accordance with the National VET Provider Collection Data Requirements Policy.

11. Compliant testamurs, statement of attainment and record of results

The RTO must ensure it is issuing compliant testamurs, statement of attainment and record of results to all eligible students

12. Collection and reporting of Quality Indicators and Total VET activity data

The Data Provision Requirements 2012 requires all registered training organisations (RTOs) registered with ASQA to provide an annual summary report of their performance against the learner engagement and employer satisfaction quality indicators to ASQA. You must also make sure, your organisation has recording and reporting Total VET activity data according to the requirements of NCVER and regulatory bodies. Your RTO is required to meet these data provision requirements as a condition of registration. Regulatory body may impose regulatory penalties if your RTO does not meet these data provision requirements.

Unpacking ASQA audit reports and files (Part 4)

Posted on by Sukh Sandhu

This is part 4 of a series. We are referring here to cases from different audits conducted by the Australian Skills Quality Authority (ASQA).
1. Units made compliant, qualifications become non-compliant
ASQA making decisions, where individual units were made compliant but qualifications including the very same units were made non-compliant. 

When we read auditor’s response the situation becomes quite interesting: 

2. ASQA officers contradicting what the ASQA auditor wrote in the initial audit reports 
ASQA officer stating that the RTO initially applied for classroom delivery and then changed to online and  rejected the application. The initial audit report had completely different statement by the initial ASQA auditor which demonstrates that there was never a proposal for classroom delivery and it was always a proposal of online delivery or online blended. 

3. ASQA refusing an application based upon the opinion that the RTO does not have intention to work with the regulatory body or was it the other way around? ASQA seems to have no intention to work with the people and organisations who question their conduct.  

4. ASQA submitted this highly ridiculous comment to the Administrative Appeals Tribunal where they stated that the CEO of an organisation does not have enough VET knowledge and advised to do some further courses in the vocational education and training sector, before reapplying for the RTO. The same CEO was deemed compliant by a previous ASQA auditor on trainers and assessors credentials such as vocational competency, training and assessment competency, Vet sector knowledge and skills (including competency based training and assessment) and professional development, industry skills and practices. 

5. Unachievable requests and bullying conduct in audit. 

6. Auditor suggesting documents to be emailed after the audit (as the auditor did not get time to go through all documents during audit) and then refusing to accept the submission. 

7. Not understanding the difference between learner resources and the industry currency documents of a trainer. Using industry currency documents of trainers to pass on training package and compliance judgements on the learner and assessment resources

8. Receiving copies of resources and then claiming that they were not received.  Did it occur or not? 

9. A 371 pages long document of how Industry consultation was sought, collected, implemented across all operations of an RTO including training and assessment strategies and practices, resources; current industry skills of its trainers and assessors. ASQA assessing it as not sufficient for clause 1.6 of “Industry consultation” 
When there are pages and pages of information regarding how Industry consultation has been implemented: 

10. Does this make any sense? When these requirements were implemented as part of the clause 1.6 in the existing Standards for Registered Training Organisations (RTOs) 2015? If you are working as a lead regulatory officer and auditor then ASQA gives you the right to create your own requirements, interpretations and standards?

Please note, the organisation has no association with any of the individuals or organisations they engaged in the industry consultation. The ASQA officer here is stating that a 371 pages long document included “ changes of a minor nature”. We did try to search the requirements of clause 1.6: 
The RTO implements a range of strategies for industry engagement and systematically uses the outcome of that industry engagement to ensure the industry relevance of:

  • a) its training and assessment strategies, practices and resources

  • b) the current industry skills of its trainers and assessors.

We could not find any information on singular or plural approach, who the individuals or organisations should be for industry consultation, the difference between minor and major changes, changes in the training methodologies and its requirements, and comment on employment outcomes for graduates. 
We even looked into ASQA’s User’s Guide to the Standards for RTOs 2015 and found simply nothing https://www.asqa.gov.au/standards
Maybe ASQA’s auditors can shed some light on these new requirements?

Unpacking ASQA audit reports and files (Part 3)

Posted on by Sukh Sandhu

Let’s look into what is actually going on in the audits and ASQA practices. This is part 3 of the ongoing series. We are referring here a number of cases from the different audits conducted by the Australian  Skills Quality Authority (ASQA). 

1. ASQA officers justifying their statements using information that contradicts all documented and credible evidence.

 

2. Maybe understanding the training package requirements and course entry requirements to enrol into a course might help. 

 

3. Targeting the RTO’s based on the training and assessment resource provider they use!! Referring to the resource provider names in the official documents submitted to Administrative Appeals Tribunal (AAT).  

 

4. Assessment resources are non-compliant because an Auditor has said so? 

 

5. ASQA questioning the credibility of RTO staff by using completely incorrect and ridiculous information  

 

6. Industry suggested feedback implemented and all clauses made compliant except the main clause 1.6 of “Industry consultation” 

 

7. How can you make up your mind before auditing an organisation? What is the purpose of audit then? Is the audit merely a bureaucratic process? 

 

8. Incompetency to its highest level 

 

9. Using the Financial Viability Risk Assessment clauses for malicious reasons. You cancel the RTO registration,  you wait until the RTOs have no other options than to shut down their operations and wind-up their businesses. 

 

10. Being part of practices that are not part of any regulatory activities

Questions raised: 

  1. Do you believe that ASQA is repeatedly and knowingly violating the NVR Act, 2011 and wilfully abused process in its dealing with scores, if not hundreds, of quality private RTOs?  

  2. Do you think ASQA has been attempting, and sometimes even been successful, in gaming the outcomes at the Administrative Appeals Tribunal (AAT)?

  3. Does this reflect the conduct of a model litigant and regulatory body in the 21st century? 

  4. Has it been exploiting the Standards and using excessive delays to impose additional financial and personal stress on RTO owners, senior managers and all other employees? 

  5. Who are the people behind these decisions, conducts and acts of injustice and corruption? 

  6. Why has the Australian taxpayer’s money been used to fight these cases in the Administrative Appeals Tribunal? 

 

Most importantly:                  

How have ASQA’s Solicitors, General Managers, Managers and Commissioners got away with this conduct for so long?

Unpacking ASQA audit reports and files (Part 1)

Posted on by Sukh Sandhu

Let’s look into what is actually going on in the audits and ASQA practices. We are referring here a number of examples from the audits conducted and the matters discussed in the Administrative Appeals Tribunal by the Australian  Skills Quality Authority. 

1. ASQA Auditor considering online documents on a Google drive as “Student Portal” and “Learning Management System”, and using these links to pass on their professional judgement: 

 

2. How can a trainer/assessor who has been deemed 100% compliant in an audit of one RTO become non-compliant in the same week for another RTO? 

 

3. Auditors trying to change the “spiky profile” developed under Australian Core Skills Framework (ACSF) guidelines during the audit:

 

4. ASQA auditors making a training organisation non-compliant on marketing standards because they did not use “currency” when they were using the most current AQF code and AQF title for all qualifications.  

 

5. Auditors trying to add their preferences, choices and expectations completely outside the regulatory framework and guidelines in an audit: 

 

6. How something not provided to the auditors can be reviewed on the same evening? 

 

7. Finding non-compliance in the areas actually not non-compliant: 

 

8. Auditors asking something not part of any legislative or regulatory framework or guidelines: 

 

 

9. Refusing application of an RTO because ASQA could not identify a trainer exists or not within the organisation:

 

10. “Conflict of interest” anyone? 

 

The auditors and officers involved in making all these decisions are still part of the Australian Skills Quality Authority. Why did no one question the competence of these officers? Have they been provided with any professional development or much needed training?

Why is so much money wasted fighting these kinds of matters in the Administrative Appeals Tribunal? 

A number of critical questions coming from these kinds of audit reports are as follows: 

  1. How is the VET Regulator is currently encouraging or promoting confidence in their practices, ethics and values? 

  2. What kind of regulatory auditing is going on at present? 

Please note: The names and other relevant information has been blacked-out to maintain the privacy and confidentiality of the individuals. 

What has been your experience with the current regulators and legislative guidelines and instruments? Share your views with us via email info@caqa.com.au.

Internal audits and why they are so important (Part 5 of 5)

Posted on by Sukh Sandhu

In the first five parts of this series we discussed the following: 

  • What are internal audits?
  • What are the benefits of conducting internal audits?
  • What is an audit scope?
  • What is usually included in an RTO internal audit?
  • Who can be an internal auditor?
  • Compliance costs and risks in terms of “risk management”
  • The effective internal audit function
  • The requirement of conducting internal audits
  • The quality system of an RTO 
  • Planning for internal audit and considerations 
  • Conducting and recording an actual internal audit

This is our special edition on frequently asked questions and answers on internal audits. We have selected the top 10 questions from the list of questions sent to us by educational institutes. 

Q1: Why are RTO internal audits important?  

Answer: Internal audits are a significant element of an RTO quality management system to ensure RTO practices and procedures meet the regulatory and legislative standards and requirements. These audits can help to monitor the RTO system and to check that compliance and norms are complied with. The aim of an internal audit is to collect data on the quality system’s performance and effectiveness. Internal audits also increase productivity, detect non-compliance and non-conformities, and evaluate the RTO’s internal control including its corporate governance and processes.

Q2: Why should I have an external audit to review my RTO’s quality management system? 

Answer: There are a number of benefits of organising an external audit by expert RTO consultants: 

External auditors are independent of the organisation and review the systems and processes based upon their extensive experience and auditing background. They are impartial and unbiased in their approach and follow documented processes and procedures to provide opinions and advice on RTO’s quality management system.

The benefits of organising an external audit includes: 

  • Advice on critical RTO non-compliance, efficient controls and compliance procedures, identification of best practices, reduction of operational costs, and the realisation of possibilities for profit enhancement.
  • Potential important savings on internal audit expenses, in particular for organisations with multiple offices and courses, high internal audit resource turnover or different levels of internal audit activities.
  • Access to the correct abilities, in the correct position, in the correct location, at the correct moment.
  • Shifting expenses to the consultancy company to develop and maintain the internal audit capacity and freeing capital and resources for key company reasons.
  • Overcoming difficulties for human resources-attracting and retaining talent, maintaining expertise on changing hazards and developing value-making abilities.
  • Alignment of strategic goals of the internal audit function with important business processes.
  • Overall risk management review, tracking of compliance and corporate performance.

Audits should be conducted by RTO experts that have extensive and current ASQA and other regulatory experience and who do not have any conflict of interest with the organisation. 

Q3: What should be the qualifications and work experience of an RTO consultant? 

Answer: We suggest that an RTO auditor should hold the Diploma of Quality Auditing, Diploma of Vocational Education and Training, Diploma of Training Design and Development or have at least 5 years of experience in RTO audits and administration. 

You must also ask and verify the success rate of the RTO consultant to ensure you receive the best advice and consultancy services. 

Q4: How long does an external audit takes? 

Answer: It depends upon your RTO’s scope and requirements to conduct an audit. Usually, two days are recommended for an RTO with two to ten qualifications on their scope. 

Q5: How should an RTO audit be conducted? 

Answer: The RTO audit should be conducted using a proper checklist and documented procedures and processes. 

Preparation of a plan that shows how your audit activities are systematic, independent and that you have a documented process for obtaining audit evidence is critical for a successful and valid internal audit. 

Q6: What is included in an RTO’s quality management system?

Answer: The RTO’s quality management system must include, but is not limited to the following:

  • The required policies and their accompanying procedures
  • Forms, templates, checklists and flowcharts to support the implementation of policies and procedures
  • Central registers to track and record your compliance activities
  • A compliance matrix that maps how each policy, procedure, form, template etc is related to the Standards.
  • Continuous improvement processes and practices

Q7: What is the usual cost of conducting an internal audit by external auditors and/or consultants? 

Answer: Different consultants have different prices depending upon their expertise and experience. CAQA auditors and consultants charge $5200 plus GST for a two day audit. This price is valid at the time of printing – 1 July 2019. 

Q8: Why you need a CAQA auditor to conduct a health check of your RTO or educational institute? 

Answer: We are experts in RTO audits. We have highly trained and experienced compliance consultants who have worked in the VET sector for more than 20 years.

A VET health check is crucial in ensuring quality RTO systems and procedures are in place and are ready for an audit for registration, re-registration, continuous improvement or internal annual audit purposes. Every RTO must comply with the Standards for Registered Training Organisations 2015:

  • Compliance with the pre-enrolment and enrolment requirements
  • Marketing and advertising
  • Third-party services  
  • Maintenance of trainer and assessor currency
  • Compliant assessment system 
  • Complaints and appeals 
  • Validation of assessment resources 
  • Management of continuous improvement
  • Student support and welfare
  • Responsive to industry and learner needs
  • Quality assurance
  • Secure and accurate certification
  • Accessible information about services
  • Informed and protected learners
  • Fair complaints handling
  • Effective governance and administration
  • Legal compliance
  • Fit and proper person requirements
  • Financial viability
  • Business planning and direction etc.

Q9: What legislation or standards do CAQA auditors and consultants have experience in? 

Answer: 

  • Standards for RTOs 2015
  • AQTF and VRQA Guidelines (VRQA registered RTOs)
  • The VET Quality Framework (ASQA registered RTOs)
  • The ESOS Act and the National Code (CRICOS)
  • VET Student Loans (Higher Education Support Act).
  • Skills First (Victoria), Smart and Skilled (NSW),  and other state funded contracts
  • ISO 9001:2015 – world’s leading Management System Standard
  • English Language Intensive Courses for Overseas Students (ELICOS)  
  • NEAS (accreditation and quality assurance services in English language teaching)
  • Australian Nursing and Midwifery Accreditation Council (ANMAC)
  • Worksafe 

Q10: How do CAQA auditors and consultants conduct an internal audit?

Answer: The process involves the following: 

  • Meet with you to discuss your specific requirements and needs
  • Scope what you need to do and recommend a path forward
  • Provide qualified auditors to advise on compliance issues
  • Work with you to ensure your systems, processes, materials and practices are resilient enough to withstand the test of an audit
  • Advise you of all the issues we find as a result of our audit
  • Advise you in writing and implementing your quality policies and procedures
  • Develop a plan to address all your non-compliant issues with a suitable timetable
  • Provide a report for you detailing the above.
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