Here we are now, six months in from the implementation of the new Standards for RTO’s. Since the beginning of the year we have conducted 17 Mock Audits and attended 12 ASQA Audits, its been a busy year to say the least. The great news is that our policies, procedures and documentation has been 100% compliant at every ASQA Audit this year, which is very exciting for our clients and the Vivacity team. In this edition of the Auditors Desk I thought you would get the most benefit if I provided you with the “Top Six Tips” on what ASQA have been targeting at audit.
Vivacity’s “Top Six Tips”:
1. Assessment Tools – This has always been a high non-compliance area and it continues to be under the new standards. Assessment tools that do not meet the Performance Criteria or the Assessment requirements of the Unit of Competency is where most of the non-compliances have been found this year. The best way to avoid non-compliances in your assessment tools is to validate them before you commence using them, which is not always possible, but a necessity. A common myth is “If we purchase our assessment tools from a Publisher, they should be compliant”, this is not true, even the Publishers tell you in their contracts that it is the RTO’s responsibility to contextualise the tools. Some good publishers, which are the ones we recommend, will guarantee their assessment tools are audit compliant and if they are not compliant at audit they will rectify the tools to meet the audit requirements.
2. Training and Assessment Strategies – The biggest change in the TAS has been Volume of Learning. The TAS should include how you have met the new Volume of Learning requirements, including the required hours for each qualification level (ie Certificate III should be delivered in one year, not the common 10-20 week period that most RTO’s offer). Another important component of the TAS should be the methodology on how you plan to deliver and assess, this should include either a Delivery or Session Plan, that outlines the units you will be delivering and how you will be delivering them. If your plan is not clear, you will be non-compliant.
3. Trainers & Assessors Quals – This is another area that still has high non-compliances. Your Trainers/Assessors must have a minimum of 3 years industry experience (this is not documented anywhere in the Standards, 3 years is based on what we are hearing at audit), not only should they have experience within their industry, they specifically should have experience in each Unit of Competency (UOC) that they deliver. Your Staff Matrix should include all the skills and knowledge that your Trainer/Assessor has that are matched against the Performance Criteria of each UOC, if they do not have this minimum skills and knowledge, find another trainer or develop a Professional Development plan to ensure that they do acquire the skills. A common area of non-compliance is Trainers and Assessors who do not have currency in the VET sector, this is professional development that the Trainer has undertaken to develop their training and assessment skills, such a simple area to fix but so many trainers do not keep their skills and knowledge up to date.
4. Delivery Plans – As stated above, a Delivery Plan or Session Plan should clearly outline to your Trainer and Student how the training will be delivered and assessed, so that it is clear what the trainer is to do and the expectations of the student. It should clearly outline the units you will deliver for the qualification and include all the assessments and a timetable of when the assessments are due.
5. Assessment Validation – With the new Clauses on Assessment Validation (1.9-1.10), a strategy should be in place on how you will manage your Assessment Validation, including a schedule of when you will validate your tools over a 5 year period, which should be validated in order of each units risk rating. You should also have in your strategy Who will be on your Assessment Validation Scheme, specifically that the Assessment Validation team includes qualified and experienced staff who meet the requirements of the Clauses.
6. Complaints & Appeals – The new areas that should be included in your Complaints and Appeals Policy and Procedure (Standard 6) is how will you ensure that a complaint or appeal is acknowledged in writing and meets the Principles of Natural Justice, which basically means that you have a process that ensures that the complaints and appeals process is clear for the student and provides a clear process for students to make a complaint to a third party if your organisational process is not sufficient.
The best way to identify how your RTO meets the requirements of the Standards, is by having someone external from your RTO conduct an Internal Audit, someone who is not part of your culture or organisation, someone who can take an un-biased view or your organisations systems and practices. It is amazing how easy it is for your organisation to become complacent against the standards, particularly when there has been a massive change in the Standards. In the last five years alone there has been 3 changes in legislation, which means that if you last updated your policies and procedures a year ago, they will be non-compliant.
We have had an excellent response from ASQA with our new policies and procedures, which have been written against the new Standards for RTO’s 2015. So far this year we have had 7 ASQA Audits, with our policies and procedures being 100% compliant at all audits so far, this is a great achievement that we are very proud to boast.
Once again this year, ASQA have a big focus on Assessment Tools and Trainers Skills and Experience, but we have also noticed a much bigger push towards Industry Engagement, with the most important factor being “how have you consulted with industry and how have you taken the feedback from consultation to improve your training and assessment practices”. Your industry consultation should be incorporated into your Training and Assessment Strategy, and we have found that the Auditors are very much focussed on what you have included in your TAS regarding improving your training based on the feedback you have received from consultation. This consultation could include Surveys that you have conducted, but also meetings you have had with industry. With most RTO’s we find that they are often collecting data from industry, but they cannot provide evidence of how they have utilised the data collected to improve their practices, the TAS is the perfect place for providing evidence of effective Industry Engagement. With all our clients, we have a systematic approach to Industry Engagement, which allows the client to develop a TAS that is much more effective during audits.
Other areas that we are finding the Auditors are focussing, is on the new requirements of the standards, in particular Assessment Validation, Complaints and Appeals and how you manage Third Parties. We have paid particular attention on updating these within our policies and procedures to ensure that we are compliant.
The Australian Government has released Draft Standards for Training Providers and VET Regulators that is due to commence 1 January 2015. The focus by the government was to streamline the standards so that they are flexible and responsive to industry and can provide Australians with skills they need to do their jobs now and into the future.
The Government is asking that RTO’s and interested industry bodies (Vivacity RTO Coaching & Consulting being one) review and provide feedback on the Standards. We have undertaken a review and have found the following:
- 8 Standards
- 54 Elements
- 6 Schedules
where the RTO is to demonstrate compliance against.
There are 5 areas that we have identified as new:
- If you are delivering Certificate IV in Training and Assessment, you will now be required to undergo External Validation
- There are new Trainers requirements that will be rolled out over a couple of years, including the level of qualification they are to hold and more emphasis on Professional Development of the Trainers
- New requirements around Marketing, which aligns with the Ethical Marketing requirements. This Standard is much more descriptive than the previous marketing Standard.
- RTO’s will be required to report Annually to the National VET Regulator, more than the standard Quality Indicators and AVETMISS reporting. In the new standard “8.4”, it states that the “RTO will declare to the VET Regulator annually that its operations meet these standards”.
- There is a bigger emphasis on the Fit and Proper Person Requirements
Following are what we found are proposed changes in the standards that are significantly different from the old standards:
- There is no new Standard equivalent to the old Standard 7.2, whereby Senior Management are required to make an informed decision based on the experiences of trainers.
- Standard 8.1 seems to be removed, whereby new applicants are required to undertake a Self Assessment (which we believe is obsolete, due to how long it takes to get to audit a lot of changes can occur from when an applicant completes the Self Assessment to audit)
- Standards 16.6, 17.4 and 23.3, where they referred to Records Management requirements, have now been combined
- Standards 16.1 and 16.5 have been combined, which we found Auditors would generally audit these two standards together
- Standards 15.1, 16.2 and 17.2, where they referred to Continuous Improvement Strategies, have now been combined. (Don’t know why these were separated in the first place…)
- There are much more stringent requirements around Partnerships and how the RTO will monitor and audit the Partner, which we agree needed to be put into place
- Changes to Fee Protection measures, where Option C from SNR 22.3 has been changed, the RTO is now required to also have either
- An unconditional financial guarantee from a bank, or
- Membership with a Tuition Assurance Scheme, or
- Any other fee protection measure approved by the VET Regulator
- A “Cooling Off” period is proposed to be added for students
During the many ASQA audits that we have experienced since ASQA’s inception, we have found that the Auditors are inconsistent with their responses to what is required of the Standards, with there being a vast difference between what an Auditor will deem compliant and not compliant with the same Policies and Procedures.
From our review of the Standards, we have found that the new standards are much more descriptive, which will assist RTO’s to address the requirements with a better understanding of what will be audited. With the Standards being much more descriptive, you would hope that there will be more consistencies between the auditors when it comes to audit.
Our CEO Angela Connell-Holden will be speaking at the VELG Conference in September 2014 on “The VET Reform – How it will impact your RTO”. We look forward to seeing you at the conference. For more details go to: https://www.velgtraining.com/nvc