Where are we going and why are we here?

If you have followed the recent discussion on social media ASQA’s practices, RTO closures, TAFE non-compliance, rorting of government funding (by now this is historical data being republished) it is one thing that stands out; students are not part of the discussion.

How did we arrive where we are at this point in time?

ASQA was set up in 2011 by the Labor Government. ASQA is completely independent and ASQA’s practices and existence can only be changed with a change of legislation. There is no doubt that some ASQA officers and auditors have acted outside their guidelines and that in the great “culling” of numbers many good RTOs have been closed down as well as some RTOs with really bad practices.  

It is, however, a bit of a surprise to see large non-compliant RTOs with bad practices come back from the brink of death and be resurrected.  Even after there have been clear breaches of the law and involvement of AFP somehow there has been survival eg. Is it because of enough money put in the right places miracles do happen?

Many TAFE`s have been found to be non-compliant in their practices and even now we hear stories from trainers who have been asked to deliver training at TAFE`s who require the trainer to “make up” their own training and assessment material. The recent promotion for apprenticeships where the picture shows a blatant disregard for basic WHS for a person working at heights did not paint a positive picture of how the VET system works.

There is no doubt that the move from employing full-time and part-time trainers to contractor positions has undermined the quality of the VET system. No job security, no annual leave, no super, no paid public holidays, no chance of being approved for a bank loan etc has meant that many experienced people have left to go back to the industry they came from.  Simultaneously, Australia is experiencing a building boom and there is a huge shortage of experienced trainers in the traditional trades areas.

The TAE qualification has been butchered to death and currently does not produce trainers with even the most basic idea of how to educate students. Qualifications completed in the shortest possible time, with minimum industry experience and to top it off a substandard trainer qualification is not a recipe for producing engaging competent trainers. No wonder we need to produce assessment material with “model” answers. How else would the trainers know what they need to assess students against?

Fees and funding for students are linked to outcomes and completions. Regardless of where a trainer is employed, in private RTOs, Tafe or Universities trainers are pressured to sign off students as competent. The only qualifications that have kept up the standards of the graduates are the qualifications where industry keeps a tight rein on who gets licensed and who doesn’t.

As we all know, politics is everything and with enough pressure, even the ABC will pull a current story, replace it with a “rorting scandal” and dig up a story about one RTO that is over 3 years old. 

Those of us that have been around the block all know that this was not the first time government funding has been rorted. There had already been the scandal when every man and his dog was signed in to Cert III IT and traineeship funding was claimed by 100’s of employers. (Who can forget the Workskills vouchers?)  There were so many warnings before the VET-Fee help scheme was launched but no one was listening and the outcome was no surprise.

ASQA auditors have pushed training and assessment into a corner where learning material is written not to inspire and educate students but in a manner that will keep an auditor happy. To pacify auditors we make up waddles of text published on paper in an era when everything you want to know about anything is already available online and for the most part free of cost. 

We also write assessments for auditors although to this day we have yet to see a version that all auditors can agree is compliant. We have evidence to show that when six ASQA auditors validated the same assessment from 1 unit of competency in different RTOs, five of made it compliant and the sixth one didn’t.  The feedback from the six did not make sense as they all thought different parts of the assessment could be improved (how is that for consistency?) and for the same section the comment from one auditor was that there was not enough information for the student and other auditors commented on the same section saying that there was too much information. It is also incomprehensible how training and assessment material audited 2 years ago and assessed as compliant can be re-audited and be non-compliant in a training package that has not changed.

The children of Australia go through an education system where teachers tell them to do their own research, evaluate information and draw their own conclusions.  Do this and become a self-motivated life-long learner. Then we send them to do Certificate III in whatever and give them learning material for 15 units of competency when 50% of the content is repeated because that’s how the auditors want it. No wonder they don’t want to come to class. Should auditors audit learning material? Does it matter how, when and where the student has acquired the learning? 

If you are following the VET debate on social media you would know that there is a war and that the battle lines are drawn. 

But where are the students in this conversation……..

Isn’t it a fact that education and training in its traditional form is fast losing its relevance and appeal?  Is the Australian VET sector becoming a dinosaur? 

The review of ASQA called for by Minister Michaelia Cash and the current petition on the Australian Parliament website calling for an investigation of ASQA will hopefully lead to a better regulatory system. As educators in the VET sector we are all familiar with the benefits and context of continuous improvement and this should apply across the board and include ASQA. If you have not already, sign the petition now. This is your opportunity to be part of building a better VET system. 

The link for the petition can be found below:


Is natural justice or procedural fairness possible with the current set up of ASQA?

We have evaluated how fair and transparent the internal workings of Australian Skills Quality Authority (ASQA) is. Where can an RTO go to complain and seek justice? How effective are the “external avenues”? 

ASQA’s auditors on the day of the audit 

Please note: ASQA has engaged some very professional officers and auditors as well and we highly respect their integrity, values and ethics. No one should have any issues with auditors if they are compliant with the regulatory standards and expectations, legislative and regulatory requirements and expectations from their job-role and status.    

However, some auditors, high on the dose of power of being an auditor come across as unchallengeable even when they do not have industry experience and audit outside their scope.. Their approach to the audit has been to treat the RTO as if a crime has been committed and view them as guilty until proven innocent. There are records of comments being passed that many would view as unprofessional, offensive and derogatory. 

One TAFE person mentioned a particular incidence where an auditor in his 30’s had to repeat his questions twice to an industry trainer in his late 70’s (with 40 years of experience in the VET Industry). The auditor got annoyed that the trainer did not hear him or understood the question the first time around and said ” I’m not sure which planet he is from”. 

Why has an environment been created and even promoted for auditors and officers to behave and act in this way? Can the culture be changed? 

If the auditors are unapproachable and unaccountable, the RTO does not get the opportunity to lodge an informal complaint and resolve any concerns during the audit. 

ASQA’s Governance, Policy and Quality team

Assume that you have a genuine complaint that has not been resolved informally during the audit and you now want to lodge a formal complaint. 

ASQA’s Governance, Policy and Quality department  is responsible for the investigation. 

You assume that this department, as it is mentioned on ASQA’s website operates independently from ASQA’s operational units and they will genuinely look into your complaint, investigate and provide you with a detailed response of the outcome. After all it is in everyone’s interest to continuously improve practice.

Many RTOs who have contacted us have, however, told us that their experience is that this department will try their very best to bury the evidence, take in excess of 90 days to finalise a complaint and when it gets back to you, it supports ASQA’s decision. 

In our investigation, we have come across a number of investigations conducted by the Governance, Policy and Quality team, where credible evidence has been given to them to investigate.  They simply refused to acknowledge this evidence or just relied on the version given of the person or persons who the complaint is against. 

We are interested to know how many times ASQA’s Governance, Policy and Quality team has genuinely investigated a matter and what the outcomes of the investigations have been. 

The information that we have received is that if RTOs get told that everything was done correctly with regards to their case and if they are not satisfied with the outcome of the investigation they can go to the Commonwealth Ombudsman. 

Right of access under the FOI Act

You then apply to get information through a Freedom of Information (FOI) request to understand what is going on and why a regulatory body is involved in this type of practice. 

The Freedom of Information Act 1982 (the FOI Act) seeks to give the Australian community access to information held by the Australian Government. ASQA manages requests for information in accordance with the guidelines issued by the Australian Information Commissioner under s93A of the FOI Act.

Guess, who has the power to release Freedom of Information (FOI) information to you? 

Gold coins if you guessed it correctly!  Yes, ASQA’s so-called independently operating Governance, Policy and Quality unit. 

If they were not able to investigate your complaint appropriately and correctly, then what information would they release under freedom of information act?  

You guessed it right, you are likely to get nothing. 

Their best route is sec 24AA, that states  “the request of releasing the information would substantially and unreasonably divert the resources of the agency from its other operations”.  

This is the common reason most government agencies refuse FOI applications.

24AA When does a practical refusal reason exists?

The Act contains two practical refusal reasons. The first is that processing the request would substantially and unreasonably divert the resources of the agency from its other operations (s.24AA(1)(a)). An agency may also refuse an FOI request if the agency is satisfied that the request does not provide such information concerning the document as is reasonably necessary to enable a responsible officer of the agency to identify the document in question (s.24AA(1)(b)). 

Even if they release any information to you, it will not be useful to you. 

You then request a Freedom of Information dispute resolution to obtain the documents from ASQA through the Office of the Australian Information Commissioner and you are advised that you must wait a year for an officer to become available and conduct the review.

Commonwealth Ombudsman 

ASQA’s Governance, Policy and Quality team provides you an option to lodge your complaint to the Commonwealth Ombudsman. 

You lodge a formal complaint with the Commonwealth Ombudsman but you are advised that they cannot investigate your contentions because it would only have been possible at the immediate time or alternatively they can not think of any better outcome in your particular matter. 

Ministerial intervention 

Ministers are helpless and incapacitated as ASQA has been set-up as an independent statutory regulatory body. 

You realise this when you contact them and ask for help and  you will get one of these outcomes: 

  • No reply as they do not understand much of vocational education and training sector, 

  • ASQA is doing the right thing and pursuing some kind of investigation on your RTO 

  • They understand and know how rogue the regulatory body is but they tell you they can not do anything until they change the legislation and regulatory standards 


You may apply for a Ministerial intervention but in most cases, Ministers simply takes advice from the Regulator itself and of course, you receive a one-pager stating ASQA did nothing wrong. 

Case closed. 

What do you do then and what help is available? 

Do not lose hope! Read our article Who is there to support training organisations and what RTO representatives should know.

Concerns about the competency levels of Australian Skills Quality Authority (ASQA) officers and auditors

The VET industry has some serious concerns regarding the competency of ASQA’s officers and auditors. We would like to look into this with some facts, records and figures. 

Qualified auditors with Senior VET Experience – are they qualified enough?

Unfortunately, the regulatory body has moved away from recruiting officers with a background in the education sector or even relevant industry experience to be able to effectively audit training organisations. Now questions have to be asked with regards to how auditors are selected and engaged by ASQA. 

ASQA hires Lead Regulatory Officers to lead and supervise audit teams; make recommendations about RTOs compliance; make recommendations for the Commissioners but, as shown below, successful applicants are not required to hold the legislated mandatory qualifications.

If applicants do not hold the legislated qualifications at the time of engagement what process does ASQA use to put their regulatory staff through their qualifications? 

According to AQF guidelines, Certificate IV and Diploma require a minimum of 1.5 years/1800 hours, up to 4 years in total/4800 hours to complete. So, does that mean that ASQA staff receive 4 years of training before they are in a position to recommend the shut down of Australian companies? Who issues the qualifications? Who are the RTOs?

When Mark Paterson, AO, commented on the first-ever strategic review as Chief Commissioner, “a review of issues relating to unduly short training”, did anyone review ASQA’s own recruitment practices or compliance with the Australian Qualifications Framework (AQF) and other relevant guidelines? 

Auditor interpretation and decision consistency: Forget nationally consistent decisions, two auditors cannot reach the same decisions  

No two auditors think or act the same way. We were shocked to see how inconsistent their findings and views are on the same clause and regulatory standard. If these auditors have such a difference in opinions then how can a regulatory body comply to its core values and source or even its existence? 

ASQA was established on the following grounds under the National Vocational Education and Training Regulator Act 2011: 

The Section 2A Objects of the Act: 

The objects of this Act are:

(a)  to provide for national consistency in the regulation of vocational education and training (VET); and

(b)  to regulate VET using:

(i)  a standards‑based quality framework; and

(ii)  risk assessments, where appropriate; and

(c)  to protect and enhance:

(i)  quality, flexibility and innovation in VET; and

(ii)  Australia’s reputation for VET nationally and internationally; and

(d)  to provide a regulatory framework that encourages and promotes a VET system that is appropriate to meet Australia’s social and economic needs for a highly educated and skilled population; and

(e)  to protect students undertaking, or proposing to undertake, Australian VET by ensuring the provision of quality VET; and

(f)  to facilitate access to accurate information relating to the quality of VET.

A common misconception in the industry is that ASQA exists to protect and promote quality in the sector.  However, the act clearly outlines, it exists to protect and enhance quality, it exists to provide national consistency in its decisions, it exists to encourage and promote a VET system that provides quality, flexibility and innovation. 

We believe all decisions where two auditors have not reached the same conclusion or outcome should be considered as “null and void”. These decisions should not have any legal or ethical standing. 

Not having nationally consistent decisions – Are not these clear signs of the incompetence of the regulatory officers and auditors? 

If two auditors cannot agree on something and provide completely contradictory statements and judgements, then how can this current regulatory body provide for national consistency in the regulation of vocational education and training (VET); and regulate VET using: (i) a standards‑based quality framework; and (ii) risk assessments, where appropriate; and (c) to protect and enhance: (i) quality, flexibility and innovation in VET; and (ii) Australia’s reputation for VET nationally and internationally; and (d) to provide a regulatory framework that encourages and promotes a VET system that is appropriate to meet Australia’s social and economic needs for a highly educated and skilled population; and (e)  to protect students undertaking, or proposing to undertake, Australian VET by ensuring the provision of quality VET; and (f) to facilitate access to accurate information relating to the quality of VET. 

How many of these requirements is ASQA currently meeting? 

Is ASQA able to provide national consistency in the regulation of vocational education and training (VET) even after eight years of registration? 

Is ASQA able to regulate VET using a standards‑based quality framework; and risk assessments? 

Is ASQA able to protect and enhance (i) quality, flexibility and innovation in VET; and (ii)  Australia’s reputation for VET nationally and internationally?

Is ASQA able to provide a regulatory framework that encourages and promotes a VET system that is appropriate to meet Australia’s social and economic needs for a highly educated and skilled population?

Is ASQA able to protect students undertaking, or proposing to undertake, Australian VET by ensuring the provision of quality VET? 

Is ASQA able to facilitate access to accurate information relating to the quality of VET?  

Please note this situation becomes immensely interesting even when the same ASQA auditor gives two different judgements on the same resources within a period of a few months. 

Errors of gigantic portions 

  • Is ASQA allowing, encouraging and promoting its officers to make errors in so called “good faith”? 

  • Where are the performance reviews of the officers working in the vocational education and training sector? 

  • Why has no disciplinary action been taken with officers misusing their position and power? 


ASQA Audits  

  1. What kind of rigour is used to review the documents and information provided to ASQA during the audits? Who checks the documents during a desk audit? Are these auditors or ASQA officers making decisions? What checklists or criteria do they check the information against?

  2. There was a case where ASQA officers could not read the name of the RTO staff members in the ASQA auditor’s report and internal documents and refused an RTO application. What actions have been taken to ensure this doesn’t happen again? 

  3. How can ASQA review the documents of an organisation, confirm that they are compliant in writing, approve them for providing training and assessment and then six months later (after the initial audit) shut them down or use sanctions to disadvantage the RTO? 


If the training package and the qualifications have not changed and the training and assessment material was previously audited and deemed compliant, how can this be possible? Was the initial assessment of the RTOs training and assessment material not properly conducted? If an ASQA representative makes a mistake at the initial audit then who should be held responsible? If ASQA made mistakes at the following audits then where is the consistency in the system? 

ASQA Audit Practices 

  1. Why does ASQA not allow audits to be recorded? If audits are conducted in a compliant professional manner then why is this a problem? 

  2. Why are comments outside of the scope of audit allowed to be made during audits?

  3. How is ASQA ensuring procedural fairness and transparency in its decisions?

  4. What risk management approach is ASQA using? After eight years, it appears that the core issues of the VET training system have still not been resolved. 

  5. Why there is no consistency, parameters and timelines in terms of when training representatives are audited and provided with audit reports? 

  6. Are ASQA audit practices auditor-centred, rather than system-centred? Are auditors auditing outside the regulatory framework and guidelines? 


Conflict of Interest 

  1. How can an auditor, representing a Government body not a private regulatory body, be allowed to work in an organisation they have been auditing after only a six-month gap? 

  2. How can consultants be allowed to become auditors and then again go back to work as consultants in the sector and then again be engaged by ASQA? 

  3. If there are “fit and proper person requirements” for training representatives and high managerial agents, what requirements are applicable for ASQA officers and auditors? A number of these officers have been part of training organisations, either as consultants or employees, that have been closed down and had critical non-compliances and unfavourable compliance outcomes. 

  4. Why are government officers allowed to provide consultancy services to RTOs? When and where do we draw the line for a conflict of interest?


Audit Reporting 

  1.  Why are all audit reports not available on ASQA’s website? 

Industry consultation form released to assist development of VET accredited courses

ASQA has released a tool to assist in the development of VET accredited courses. The following media released has been published by Australian Skills Quality Authority: 

The Standards for VET Accredited Courses 2012 require a course developer to provide:

  • evidence of an industry need and

  • supporting evidence that industry consultation and validation of course content have taken place during course development and review stages of ASQA’s course accreditation process.


ASQA has developed an Industry consultation form (DOC) to assist course developers in meeting this requirement. The form consists of two parts:

  • the first part is to be completed by the stakeholder engaged and requires general information about that stakeholder and their responses to questions about the proposed course. ASQA will use the responses in its assessment to determine the suitability and validity of industry consultation.

  • the second part—attachment one and two—is to be completed by the course developer and circulated to industry representatives providing an overview of the proposed course information.


An example of how to complete attachments 1 and 2 of the Industry consultation form can be viewed online.

This form should be submitted to ASQA by the course developer when submitting an application for initial and/or renewal of course accreditation.

You can read more information about this by clicking the following link 


Financial Viability Risk Assessment (FVRA) tool has changed again, version 3.1.

The financial viability risk assessment (FVRA) tool has been changed again by ASQA to make it more user friendly. The latest change was implemented on October 4, 2019. The changes have been made to make the FVRA tool more user-friendly and in cases where it is incomplete, provide additional guidance to identify items missing.

The following media release has been published by the Australian Skills Quality Authority: 

In response to user feedback, ASQA has made a number of revisions to the Financial Viability Risk Assessment (FVRA) tool to make it more user friendly.

These changes will assist users in ensuring the tool is complete before they provide it to ASQA and, in cases where it is incomplete, provide additional guidance to identify items missing.

If you are required to complete and submit the FVRA tool to ASQA, you should ensure you are using the latest version and that you have provided all required attachments – these are detailed on the Provider Details tab of the FVRA tool.

ASQA may require you to demonstrate financial viability by submitting the FVRA tool at any time, or when you:

  • apply to become an RTO and/or a CRICOS provider

  • apply to change the scope of your RTO registration in the first 12 months of registration

  • change 50% or more of the ownership of your RTO within a 12 month period


You can read more information about this by clicking the following link;


I want to voice my opinion – your letters and emails to us

In this newsletter, we have selected this email received from one of our subscribers genuinely questioning the current regulatory environment of Registered Training Organisations:

“It has been my experience as an RTO Manager that everyone except the RTO is protected in the current environment.  Students and staff can complain to ASQA and Smart and Skilled about an RTO but there is no recourse for RTOs which find themselves placed in a compliance risk scenario caused by incompetent trainers.

Don’t get me wrong, I think it is very important that students and staff are protected, but there is no protection for RTOs from unscrupulous staff that are potentially harmful to the business.

We have employed staff who look great on paper, interview well, but in reality cannot do the job required and in some cases, place the RTO at compliance risk due to their lack of skills or knowledge.  The students are the ones who end up suffering and these trainers move on and inflict the same level of training and compliance risk on the next RTO.

I would love to see a review tool that all RTOs could access to share their experiences before they employ staff.”

The names and details have been removed to protect the confidentiality of the person/s involved. 

Do you have views or thoughts on this topic? How do you review a trainer’s performance and how do you know what goes on between the trainer and the students? Have you got any tips and hints that you are willing to share with this RTO Manager?

Why not write to us and discuss how we all as VET stakeholders can voice our opinions and views and help create a better vocational education and training system. 

Review of Australian Qualifications Framework (Part 1)

The AQF review, chaired by Victoria University tertiary education professor Peter Noonan, recommended a shake -up of Australia’s qualification system.  Under the recommended changes senior secondary students would also be able to study subjects at school that would count towards a vocational training qualification or university degree. The new changes will enable students to mix -and -match their subjects across universities and vocational education, to earn the qualifications they need for the jobs they want.

The review recommends recognising the diversity of post-secondary education and to offer clear and flexible entry and exit points, as well as pathways within and between VET and higher education.

What is AQF and how did it evolve? 

The AQF is the national policy for regulated qualifications.

Consider AQF as the national architecture that sets the structure for all qualifications across higher education, VET, and senior secondary schools. 

Australia was among the first countries to develop and implement a national qualifications framework. Although the structure and purposes of national qualification frameworks vary between countries, their central purpose is to ‘establish a basis for improving the quality, accessibility, linkages and public or labour market recognition of qualifications within a country and internationally’.

The AQF was introduced in 1995, replacing the former Register of Australian Tertiary Education (RATE), while drawing in elements from the Australian Standards Framework (ASF). The ASF was a vocational system of levels developed as part of the transition to competency-based training. The AQF’s first six qualifications were aligned to the first six levels of the ASF, while all the Bachelor Degree and above qualifications were carried over from the RATE. 

In Australia, a number of factors figured in the development of the AQF. The VET system was being reformed to adopt competency-based training, prompting a need for nationally recognised VET qualifications linked to competency standards. More students were completing Year 12 and there was rapid growth in the tertiary sector. This highlighted a need for greater consistency and transparency between qualifications to support recognition of prior learning (RPL) and credit transfer. 

In its initial form, the AQF was a relatively loose framework. It reflected the characteristics of the existing qualification types issued in each sector, with learning outcome levels embedded in the qualification types. The qualifications were grouped by sector and had descriptors of knowledge applying within the sector. This was in contrast to the consistent levels-based taxonomies of learning and skills used in other countries, that the AQF would adopt from 2011.

When the AQF Council was disbanded in 2014, the Commonwealth Minister for Education agreed the AQF would be reviewed within five years. From time to time,since it was introduced, the AQF has been revised to reflect or facilitate change in the education sector. Changes in the nature of work that affect the skills that graduates need and the types of qualifications that students and employers are seeking, now need to be considered for reflection in the AQF. As it is seven years since it was last formally reviewed, it is timely to consider ways in which the AQF could be improved to keep it at the forefront of best practice in qualifications frameworks internationally.

The Australian Government announced a review of the AQF in the 2017-18 budget to ensure that it continues to meet the needs of students, employers, education providers and the wider community.

The purpose of the AQF review 

The review was set up to examine the need for changes to the AQF which defines the characteristics and learning outcomes of the qualifications issued in senior secondary school, vocational education and training, and higher education.

The purpose is to look into a less complex AQF architecture, with the current ten levels of qualifications and to ensure the “overly rigid structure” is simplified and provides a more flexible options to reflect the changing nature of work and post-secondary education. 

The other purposes were: 

  • The creation of a Higher Diploma at the same level as a Bachelor degree and renaming of VET certificates to reflect their purpose

  • Recognition of microcredentials and greater fluidity between VET, higher education and schools

  • Ensure the credits earned in one area — for example, vocational education — to be put toward a higher education qualification. 

The Panel has identified three broad questions for consideration through submissions and the consultation process: 

  1. In what ways is the AQF fit, or not fit for purpose? 

  2. Where it is not fit for purpose, what reforms should be made to the AQF and what are the most urgent priorities? Please be specific, having regard to the possible approaches suggested in this paper and other approaches.

  3. In relation to approaches suggested by the Panel or proposed in submissions or through consultations, what are the major implementation issues the Review should consider? Please consider regulatory and other impacts.

Review Panel

  • Professor Peter Noonan (Chair): Professor of Tertiary Education Policy at Victoria University

  • Mr Allan Blagaich: Executive Director of School Curriculum and Standards, WA Department of Education

  • Professor Sally Kift: Adjunct Professor, College of Business, Law & Governance at James Cook University

  • Ms Megan Lilly: Head of Workforce Development, Ai Group

  • Ms Leslie Loble: Deputy Secretary, External Affairs and Regulation, NSW Department of Education

  • Professor Elizabeth More AM: Chief Education Officer, Study Group Australasia

  • Ms Marie Persson: Member, New South Wales Skills Board, Chair, NSW Skills Board Industry Reference Group, Member, Monash Commission

The earlier review processes and objectives 

The 2008 Review of Higher Education (Bradley Review) proposed that Australia should develop a more coherent tertiary education system. It noted the need for a continuum of tertiary skills and recommended a single regulator and funding source for the VET and higher education sectors. It also proposed a review of the AQF, noting the weaknesses of the AQF at the time. The Review of the AQF took place between 2009 and 2011 under the authority of the AQF Council, which was established as a result of stakeholders wanting “a stronger custodian of a stronger AQF.

In 2011, a revised AQF was implemented, including a more consistent taxonomy of learning outcomes. The taxonomy was applied to both levels and qualifications, making the AQF a more detailed and complex document. These changes envisaged enhanced governance arrangements for an AQF body to ensure compliance with the AQF. However, instead of the more integrated tertiary education system recommended by the Bradley Review, different regulatory systems have continued to evolve under separate national regulators for higher education and VET Provider standards in both sectors reference the AQF but arguably reinforce sectoral differences in qualification purpose, design and methods of teaching.  

Micro Credentials 

The review has recommended significant reform to the AQF, designed primarily to make connections and the transition between vocational education and training and higher education easier for students and education providers. Recommendations in the review also recognise ‘micro -credentials’ as valid education tools to fill a skills gap.

One-hundred-million global students — that is the major milestone finally hit in 2018 by online study units known as Massive Open Online Courses (MOOCs).

As many as 20 million learners last year joined the ranks of those studying courses on the biggest MOOC platforms, down from the 23 million who first enrolled in 2017, but with an increase among those willing to pay for the privilege.

Micro-credentials have all-ready become increasingly available through universities, with many used as a means to enhance business leaders’ technology know-how. ‘Microcredentials’ would be recognised to allow providers to offer short, highly-targeted courses to students and employers looking to fill a skills gap without getting bogged down in red tape. 

A major federal government review has opened the way for recognition of short courses, known as micro-credentials, within tertiary qualifications. The review fell short of recommending the micro-credentials should be included in the AQF, which is the taxonomy of all recognised Australian tertiary qualifications. However it said that recognising them as a valid form of credit and as prior learning which could shorten the period of study needed for a recognised qualification, would “build on current practice”. The review said that, even though the AQF should not formally include micro-credentials, it “should provide guidance on requirements for awarding credit for shorter form credentials, to ensure consistency of quality into the future”.

“This would improve confidence in the credentials by employers and industry associations and improve recognition by providers for credit purposes,” it said. 

“For students, it would provide some quality assurance, portability and consumer protection.”

The review also said that the demand for shorter credentials was expected to increase “fuelled by the necessity for lifelong learning and global competition in the supply of education and training”.

The review report is available here


Who is there to support training organisations and what RTO representatives should know. (Part 1)

In this article, we will discuss the issues registered training organisations are experiencing in their day-to-day operations.

You have the following help available: 

RTO consultants

Extend your own understanding and get an unbiased evaluation of your training and assessment from a consultant who can evaluate your practices and give you feedback.  Contact a few and ask them about their experiences dealing with compliance matters. Ask how many ASQA audits they have participated in and what the outcomes were for the RTOs they worked with. Discuss how they can help you. Experienced consultants deal with hundreds of training organisations, therefore, they can advise and guide you. Ask colleagues, peers, or your peak body for recommendations, or consider other public information to help ensure you are choosing a reputable consultant. 

Independent Tertiary Education Council Australia (ITECA):  

ITECA is actively pushing for an Australian National Audit Office (ANAO) review of ASQA in order to ensure that it is an effective regulator that faithfully enforces its regulatory framework in a timely, transparent and consistent manner.

The Independent Tertiary Education Council Australia (ITECA) is a membership-based peak body bringing together independent providers in the higher education, vocational education and training sectors. Individually and collectively these providers share a commitment to providing students and their employers with the quality outcomes they are looking for.

The ITECA Higher Education Network brings together more than half of the independent providers in the higher education sector and the membership numbers are growing. 

These independent providers deliver training to around two-thirds of all students undertaking vocational education and training in Australia.

Click the following link to find more information https://www.iteca.edu.au 

Enterprise Registered Training Organisation Association: 

ERTOA (Enterprise Registered Training Organisation Association Incorporated) is a National association representing and supporting: 

  • Organisations operating as registered training organisations (RTOs) under the Vocational Education and Training (VET) Quality Framework and who deliver training primarily to their employees and/or volunteers;​

  • Organisations who are not RTOs (or those who or engage with an external RTO) who deliver training primarily to their employees and/or volunteers; and​

  • Individuals working actively as trainers, assessors or facilitators who deliver accredited training under the VET Quality Framework. 

The organisations supported by ERTOA represent a distinct and unique component of the Australian VET sector, because they are in fact industry.   

ERTOA’s goal is to assist these organisations achieve their business needs in terms of training and development.  ERTOA also supports trainers, assessors and facilitators who work within the VET industry.

Click the following link to find more information https://www.ertoa.org.au

TAFE Directors Australia 

TAFE Directors Australia (TDA) is the peak national body that represents Australia’s 58 government-owned Technical and Further Education (TAFE) institutes, university TAFE divisions, and the Australia-Pacific Technical College (APTC).

The core business of TDA is to support members with advocacy for the important role of TAFE under state and territory jurisdictions in meeting Australia’s need for increased productivity, participation and educational attainment in the workforce. The public provider (TAFE) network provides a diverse and integral series of technical and further education services for individuals, enterprises and communities in the emerging tertiary education sector in Australia.

Key to the role of TDA is to position TAFE nationally as the major provider of high quality skills; lead policy development for TAFE and VET sectors; and to lead advocacy for improved outcomes for students. TDA conducts and commissions research and data collections in order to build a strong evidence base from which to advocate. Thus, TDA is involved in data collection and economic modelling; consumer and industry research; producing and publishing position papers in response to policy initiatives, government reviews and inquiries.

Click the following link to find more information


Community Colleges Australia (CCA)

Community Colleges Australia (CCA) lobbies for greater recognition of and enhanced support for the community education sector, to achieve the social, economic and cultural aspirations of the diverse Australian communities where our members operate.

As the national “voice” of not-for-profit community education providers, CCA advocates with a range of government portfolios on the benefits achieved by community learning provision. As the education sector continues to evolve and population demographics change, CCA encourages governments to recognise community education providers as essential community centres of “connectivity and learning”. These centres offer learning options for all, notably:

  • Education and training for persons with a disability

  • Migrants and others who need ‘second-learning’ opportunities

  • Lifelong and personal learning

  • Social inclusion for older and vulnerable people

  • Encouraging young people to participate in education and training that leads to a sustainable future, through providing employment and job readiness skills, including a growing network of not-for-profit community-based high schools

  • Health, wellbeing and care

  • Indigenous community development

  • Community safety and child protection

  • Juvenile and corrective services participants

CCA also provides “thought leadership” in public, media and community discussions, leading towards the improved recognition of and funding for community education and training in Australia.

Click the following link to find more information


We will continue with part 2 of this series in our future newsletters. 

ASQA has changed the rules for purchase and sale of RTO’s

Australian Skills Quality Authority has made it crystal clear that “Registered training organisations (RTOs) and Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS) providers are not permitted to transfer their registration from one legal entity to another. However, where a change of company shareholdings occurs, but the ABN/ACN of the entity registered with ASQA does not change, then the provider may continue as long as they notify ASQA of the change of ownership”. 

If you are involved in a change of ownership, either as disposer or acquirer, it is important you understand your obligations. These obligations are set out in the NVR Act and the ESOS Act. If your provider is only registered as an RTO, then you are required to notify ASQA of change of ownership as soon as practicable after the event. This is a requirement under s25(2) of the National Vocational Education and Training Regulator Act 2011. If your training provider is registered as a CRICOS-only provider, or as both an RTO and CRICOS provider, you must notify ASQA of a change of ownership as soon as practicable before the change takes effect.  This is a requirement under s17A (3) of the Education Services for Overseas Students Act 2000. 

ASQA is considering the registration is provided to the applicant’s ability to comply with the Vocational Education and Training (VET) Quality Framework and the Education Services for Overseas Students (ESOS) Framework (if applicable). ASQA seeks to ensure that buying into a training provider is not a way for a purchaser to circumvent the scrutiny applied to initial applications. When an entity that is an RTO changes ownership, therefore, its registration cannot transfer to a person or corporation that acquires the RTO as a different legal entity. 

Additional evidentiary requirements  

ASQA has introduced new evidentiary requirements for the following change of ownership situations. These changes are a part of ASQA’s commitment to ensuring providers are able to demonstrate regulatory compliance and are able to deliver quality outcomes for their students. 

When 50 per cent or more of a provider’s ownership changes within a 12-month period

  • Where 50 per cent or more of the ownership of a training provider—or their parent entity/ultimate owner—changes at once or over a 12-month period, additional evidence must be submitted to ASQA. In this situation, you are required to complete and provide ASQA with:•

  • a Financial Viability Risk Assessment Tool—this must be completed as a new registration (start-up) application type

  • Section A of the Self-Assessment Tool for Change of Ownership1—this must include the required supporting evidence detailed in the tool. 


When 100 per cent of a provider’s ownership changes within a 12-month period

Where a training provider—or their parent entity/ultimate owner—change 100 per cent of their shareholdings over a 12-month period, both Section A and B of the Self-Assessment Tool for Change of Ownership must be completed and submitted to ASQA if the provider has either:

  • no ongoing students, or

  • not had more than 10 students complete a course within the previous 12 months of registration


Possible consequences of change of ownership 

Compliance audits 

Where significant changes to ownership are subject to additional evidentiary requirements. ASQA will conduct a compliance audit to review that evidence. The audit will consider the training provider’s compliance with:

  • the relevant regulatory framework (VET Quality or ESOS legislative) 

  • the clauses and standards in the Self-Assessment Tool for Change of Ownership


This audit will focus on whether your training provider is, and will remain, sufficiently resourced to provide quality training and assessment, accurate information, and adequate support to students. If non-compliance is found during a compliance audit, proportionate regulatory action will be taken.

Increased scrutiny for 12 months

Training providers that have a significant change of ownership will also face additional scrutiny in the 12 months after the compliance activity is finalised.This scrutiny will be applied to any applications to change scope of registration from training providers during this period, and through a provider review at the conclusion of the period. Both of these activities may trigger regulatory action, which could include further compliance audits. 


There is no cost to lodge a notification of material change; however, a compliance audit activity triggered by a notification may incur compliance audit charges for any RTO regulated under the NVR Act. 

For further information, please refer to New guidance on change of ownership obligations: 


The Australian Government is investing $41.7 million to pilot Skills Organisations in human services care and digital technology (including cyber security) industries

The Department of Employment, Skills, Small and Family Business has published the following media release: 

The Australian Government is investing $41.7 million to pilot Skills Organisations in two key industries; human services care and digital technology (including cyber security).

The Skills Organisations Pilots will drive innovative ‘end-to-end’ training solutions and enhance the role and leadership of industry in the national training system.

The Joyce Review proposed Skills Organisations be owned by industry and take a leadership role to support the VETsystem better meet the needs of employers, the economy and learners.


The two pilots, in human services care and digital technologies, will trial new ways of working to shape the national training system to be more responsive to skills needs for those industries – from the identification of skills needs, to qualifications development, through to improving the quality of training delivery and assessment.

The pilots will be industry-led, and will trial innovative ‘end-to-end’ training solutions within the national training system. Lessons from these pilots will help inform broader improvements to the national training system.

Human Services Care

According to the Department of Employment, Skills, Small and Family businesses 2018 Employment Projections, Health Care and Social Assistance is projected to make the largest contribution of any sector to employment growth, increasing by 250,300 jobs in the next five years.

Digital Technologies

Digital technologies are essential to Australia’s economy. The number of employed ICT and telecommunications professionals is projected to increase by at least 16% by 2023, which equates to an additional 46,000 workers. In addition, the cyber security sector has estimated a need for 18,000 more employees for the sector to meet its full potential.


Alongside implementation of the two pilot Skills Organisations, the Australian Government is seeking input from stakeholders, across the VET system, to explore opportunities for ‘future-state’ Skills Organisations to improve industry leadership and employer confidence in the VET system, as well as improving quality in learner outcomes.

This information, in addition to learning from the two pilot Skills Organisations, will inform future Government decisions about the Skills Organisation model, including how this approach could deliver a VET system more responsive to industry needs and expectations.

To understand stakeholder views about the concept of establishing Skills Organisations beyond the pilots, the Department is holding national, co-design workshops with industry peak bodies, small and large employers, employee representatives and others.

The Department is seeking stakeholder views on a range of elements to understand whether and how the concept of Skills Organisations could drive improvements to employer confidence in the VET system to deliver the skills their organisations need now and into the future.

discussion paper has been created for public consultation.

Submissions do not need to respond to all questions.

Submissions close on 15 November 2019. For more information please email SkillsOrganisations@employment.gov.au.

Unless indicated otherwise, responses may be published online on the Department’s website. All comments will be considered as part of the co-design process. 

For more Information please visit https://www.employment.gov.au/SO

Beware of FAKE certificates and unregistered providers

ASQA published the following media release on October 4 2019: 

ASQA is aware that unfortunately, there are unqualified organisations issuing fake certificates in the Vocational Education and Training (VET) sector.

Whether you are a student signing up for a course in VET or a business seeking a training provider for your employees, make sure to verify the provider’s current registration status on training.gov.au.

Training.gov.au is the National Register of VET in Australia. It is the authoritative source of Nationally Recognised Training and maintains a current list of registered training organisations (RTOs) who have the approved scope to deliver Nationally Recognized Training, as required by national and jurisdictional legislation within Australia.

Updates to USI transcript for closed registered training organisations

Australian Skills Quality Authority (ASQA) published the following news on October 4 2019: 

As part of a collaboration between the Australian Department of Education, ASQA and the National Centre for Vocational Education Research (NCVER), ASQA is now able to upload the academic results from closed RTOs to students’ Unique Student Identifier (USI) transcripts outside the regular data submission windows. This allows USI transcripts to be updated for students from closed RTOs in a timely fashion.

Close to 66,000 records that were not available from closed registered training organisations (RTOs) are now reflected on the USI transcript.

The USI allows students to access their training records from different training providers, in different states, and across different years – in the one transcript online.

For more Information, please visit




Unpacking ASQA audit reports and files (Part 4)

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?