The purpose of due-diligence audits

Due diligence is an important process to learn about when considering becoming a buyer for a registered training organisation (RTO). It is essential, before investing in a registered training organisation, that you have a solid understanding of the function that due-diligence audits serve.

These audits can be carried out by experienced RTO consultants in order to evaluate the organisation’s compliance with all applicable regulatory and legislative requirements, as well as the quality of the training that is being provided by the organisation, record keeping, and so on.

The findings of the audit are analysed to determine whether or not the organisation meets the criteria necessary to provide high-quality training. If the audit finds that the organisation is not meeting the required standards, the organisation will have the opportunity to correct the compliance issues in order to meet regulatory standards and guidelines.

The process of due diligence is very important because, if a regulatory body discovers that an organisation is not complying with their requirements, the regulatory body has the authority to take action against the organisation, which may include suspending or cancelling its registration.

Audits of due diligence are an essential component in achieving the goals of ensuring that the organisation you are planning to purchase is a compliant registered training organisation and gaining an understanding of the steps required to become one.

If you are able to gain an understanding of the goals of these audits, you will be able to select a training provider in which to invest your time, energy, and resources with the confidence that you are making an educated and informed choice.

Before diving into the specifics of a due diligence audit, it is essential to have a solid foundational knowledge of the various audit procedures that can be carried out on an RTO. Only then will you be able to fully comprehend what goes into this particular type of audit. The following are the two primary categories of audits:

  1. Financial audits
  2. Compliance audits

Audits of financial records are carried out with the purpose of determining an RTO’s overall financial health and stability.

On the other hand, compliance audits are centred on determining whether or not an RTO is in accordance with the Standards and the requirements set forth by legislation.

Audits of compliance with due diligence requirements are one type of audit. Independent auditors and consultants are the ones who carry them out. An RTO’s compliance with the Standards and its ability to continue business in a financially sustainable manner are two of the primary foci of a due diligence audit, both of which are intended to serve as assurances that the audit was carried out properly.

During a due diligence audit, the auditors will look at a variety of factors, including the following:

  • The extent to which the RTO complies with the Standards
  • The financial viability of the RTO
  • The RTO’s various marketing activities and endeavours.
  • The procedures for training and assessing students at the RTO
  • Management and governance structures that are in place for the RTO.

If there is reason to believe that an RTO is not adhering to the standards, the regulatory bodies have the authority to carry out investigations and carry out audits on the RTO in question. Therefore, if you are considering buying a registered training organisation (RTO), you need to understand the following:

  • any non-compliance on the part of an RTO’s historical records and data could become a source of stress for you.
  • there may be training and assessment resources available to organisations but they may not be compliant with the regulations
  • there may not be sufficient facilities, equipment, and resources for conducting compliant training and assessments
  • Training organisations may not have compliant trainer files and records

You will benefit from a due-diligence audit because:

  • You can gain a better understanding of the efficiency with which training programmes are being run by conducting a due-diligence audit.
  • You can also gain a better understanding of stakeholders’ needs analysis by conducting a due-diligence audit.
  • An RTO can receive helpful feedback about their level of compliance with the applicable standards through a due-diligence audit.
  • You will have a great opportunity to understand the standards and requirements necessary to operate in the training and education industry if you participate in a due-diligence audit.

When an RTO is registered, it indicates that the organisation has satisfied the prerequisites necessary to begin conducting education and training business. On the other hand, this does not necessarily imply that the RTO will always be in compliance with the applicable standards and regulations. Audits of an RTO’s compliance with applicable regulations and the quality of the training it offers are absolutely necessary in order to fulfil the requirements of due diligence.

Does your registered training organisation need an audit by CAQA auditors? Feel free to reach out to us if this is the case.


Set boundaries, establish guidelines, and work within them.

Organisations providing training services have a responsibility to ensure that their activities are carried out in a manner that is compliant with the expectations of the relevant regulatory bodies. This includes setting boundaries and establishing guidelines for staff and clients.

As a training organisation, it’s important to set boundaries and establish guidelines. This will help you stay within the parameters of your organisation, and ensure that you’re providing the best possible training service to your clients and staying compliant with the regulatory requirements according to the expectations of the regulatory bodies such as ASQA.

Some boundary setting may be required in order to:

  • Maintain a comprehensive policies and procedures framework
  • Maintain high-quality training services
  • Ensure legal and ethical compliance with organisational policies and external regulation
  • Facilitate positive working relationships between trainers, trainees and clients.
  • Organisational boundaries may include:
    • Physical space: Where is training allowed to take place? Are there any dangerous areas off-limits?
    • Time: What are the start and finish times for training sessions? Is there an allotted time for breaks?
    • Materials: What materials or equipment can be used during training? Are there any dangerous materials that should be avoided?
    • Behaviour: What behaviour is expected of trainers and trainees during training sessions? Are there any rules about speaking or interacting with others?

It’s important to communicate these boundaries to all involved in the training process so that everyone is clear on what is expected of them. By setting and enforcing these boundaries, you can help to ensure a safe, positive and productive learning environment for all.

There are a few things to keep in mind when setting boundaries and establishing guidelines:

The type of organisation you are running: What are the specific requirements of the regulatory body that you need to comply with? Are there any industry-specific standards that you need to adhere to?

Your clients: What are their expectations and needs? How can you best meet those needs within the confines of your organisation’s boundaries and guidelines?

Your staff: What do they need to know in order to carry out their roles effectively? What are their capabilities and limitations?

Your resources: What do you have available to you in terms of time, money and manpower? How can you make the most of what you have available?

Define the scope of your services. What kind of training do you offer? What are your areas of expertise? Make sure that you’re clear about what you can and cannot offer so that you can set the appropriate expectations with your clients.

Make sure your boundaries are realistic. If you set too many restrictions, you’ll likely find yourself unable to provide the training that your clients need. Likewise, if you set too few boundaries, you may find yourself overstepping your bounds and causing problems for your organisation.

Be clear about what your boundaries are. Your clients should know exactly what they can and cannot do during their training sessions. This will help them stay within the bounds of your organisation, and avoid any potential misunderstandings.

Enforce your boundaries. If you find that your clients are constantly pushing the limits of your boundaries, it’s important to take action. This may mean terminating their contract or providing them with a warning.

Communicate with your clients. Throughout the training process, it’s important to keep your clients updated on your boundaries and guidelines. This will help them stay informed, and avoid any potential surprises. Make sure that all your RTO stakeholders understand what your policies are and how they will be enforced. This will help them know what to expect from your service and avoid any surprises.

Be clear about your pricing. Make sure that your clients know how much your services cost so that there are no surprises down the road.

Follow up with your clients after they’ve attended a training session. Make sure that they’re satisfied with the service that they received and address any concerns that they may have.

By following these strategies, you can ensure that you’re setting appropriate boundaries and establishing clear guidelines for your training organisation. This will help you provide the best possible service to your clients, and avoid any potential problems.

If you have any questions about setting boundaries in your training organisation, please get in touch with us today. We’d be happy to help!

Message from the CEO

Message from the CEO

We need to make sure we eliminate any issues that lead to decreased student engagement and an increase in drop-out rates. We need to think about and execute support for students who want to complete a VET qualification and follow their interests or passion. Coming out of lockdown, we will need to move to a stable economy where our graduates have the knowledge or skills that employers need.

This month we are launching our “Your questions and our answers series”, a free webinar on the last Friday of the month between 12 to 1 PM. If you have questions do not hesitate to send them to us and we will try to answer as many of them as possible during the live sessions. We have more information in the “Your questions and our answers series” article. Join us for an hour of free compliance education! All attendees will receive certificates of attendance from us.

As always, if you require assistance in any way, please contact us via email at

Sukh Sandhu

Why organisations should prioritise systematic continuous improvement as a strategic priority

Continuous improvement is one of the most important ways to ensure compliance with regulatory operations and successful organisational performance. By continuously identifying areas for improvement, education and training organisations can ensure compliance to the regulatory requirements and standards, improve their performance and also gain an edge over their competitors.

Continuous improvement requires strategic attention by leaders and a culture that prioritises continuous improvement as a strategic priority.

One of the key benefits of prioritising systematic continuous improvement is that it provides organisations with an opportunity to develop and sustain a competitive advantage in their industry or market.

In order to stay ahead of the competition, organisations should prioritise systematic continuous improvement as a strategic priority. This is because it will lead to more innovation and competitive advantage.

The term “culture of continuous learning” has been coined by Carol Dweck who defined this as “a process of creating conditions that lead to an organisation where learners are operating at their full potential”.

Organisations can achieve this by developing a new mindset that is driven by continuous improvement. This means that they will need to transform their culture into a culture that values continuous improvement. If they cannot do this, then they are in danger of becoming obsolete already in the future when new technologies come into play.

Systematic continuous improvement has many benefits like improved customer satisfaction, improved revenue generation, improved brand value and improved employee engagement.

There is a long list of reasons why organisations should prioritise systematic continuous improvement as a strategic priority. These include:

– It is an approach that celebrates change and challenges the status quo;
– Improving the performance of an organisation through improved customer service and increased revenues
– Continuous innovation and creation of new products/services for future customers
– Improved profitability
– Improved quality of life of employees
– It is a customer-focused strategy: businesses must use an innovative approach to create value for customers;
– it facilitates learning opportunities: through systematic continuous improvement, businesses can learn from mistakes and drive innovation
– Increasing profitability and performance
– Reaching a company’s goals and objectives with greater certainty
– Saving time and effort when implementing new strategies from start to finish
– Reducing the risk of making mistakes
– Making good decisions in uncertain, fast-moving environments

The most compelling reason for prioritising systematic continuous improvement is that it increases the chance of achieving the business goals.

Converting the audit quality practices to system-centred rather than individual-auditor-centred

When we talk about “audit quality practises,” we talk about the factors that influence the outcomes of audits conducted on behalf of a regulatory body, such as the behaviour of auditors, the decisions they make, the approaches they take and the way they act in order to ensure that audit outcomes are appropriate, suitable, relevant, and based on facts rather than personal opinions and biases against an individual or organisation.

In this article, we discuss a number of the components of audit quality practises that are important to consider.

Standards to audit the regulatory body and its officers

The million-dollar questions are: who audits the auditors, and can they achieve consistency in their decisions? Despite the fact that some government agencies are auditing some of their actions, the vast majority of the judgments and practises of the regulatory body go unnoticed and unanswered to anyone. A clear set of standards should be established for the regulatory body, and clear guidelines should be developed for their auditors. The audit practices, boundaries and guidelines should also be clearly defined.

External complaints resolution department

How can genuine complaints be resolved when the freedom of information (FOI) and complaints handling are controlled by the same individual and department within ASQA? Yes, these approaches are acceptable for a brief period of time in order to conceal malpractices, but for how long will they remain hidden from the rest of the industry? How can a regulatory agency establish confidence with its stakeholders if there is no credible external entity to evaluate and review its operations and procedures? On paper, the Ombudsman is there to investigate their decisions; yet, how many times have they made decisions that were against the regulating body? Where are those statistics and how do those decisions make the regulatory body change their practices? Complaints and feedback from stakeholders are opportunities to improve the system, framework, and processes. If you ignore investigating complaints and feedback from stakeholders or just have blind faith in what your auditors tell you, then you will never be able to improve any practices.

Professional development workshops for auditors

Workshops for professional development are essential for everyone in the sector, and auditors are no exception. As representatives of a government agency, they hold a position of authority and influence. As a result, they require far more professional development and personal development sessions than anybody else working in the education and training industry. Regular professional development workshops would assist them in understanding how they should strictly adhere to regulatory rules rather than rely on their own personal judgments, prejudices, and opinions to make audit decisions.

Internal validation and moderation meetings

Internal validation and moderation meetings for audit outcomes and practices are required in order to establish high-quality audit practices. Decisions should be made in accordance with what the system suggests, rather than what the individual recommends. In order to train the auditors on what can and cannot be accepted in a black and white manner, set templates, policies, practices and protocols should be used. The outcome of these moderation meetings should be shared with the industry in order to inform them of what was discussed, which tactics were changed, and why and how the strategies will affect the training organisations in question. Every time a new auditor audits the processes and documentation of a training organisation, the results should not be a surprise to the training organisation or consultants representing them in the audit.

Audit reports

The audit reports should not only cover non-compliances, but they should also include where the compliance has been found. In a number of instances, the same auditor has made different judgments over a period of a few weeks, and this type of activity should be considered unacceptable by any regulatory authority.

When it comes to audit reports, the most important purpose is to have reasonable certainty that the report as a whole is free of any misrepresentation and errors; and to ensure that any noncompliance issues that are identified are clearly reported to all parties through the audit report.

In order to ensure that all stakeholders have faith in the system and are fully informed, the quality of audit reports is vital to an effective and efficient regulatory system. The purpose of audit quality procedures is to instil confidence in the correctness and dependability of audit practises. It is vital that audit quality and consistency of audit execution be consistently enhanced in order to retain public confidence in the regulatory system.

These are just a few of the critical improvements that must be included in the new regulatory framework to ensure its success. What other changes would you like to see implemented in audit activities? Write to us and tell us about your experiences interacting with the regulatory body and your thoughts on the matter.

We are interested in listening to your suggestions, feedback and stories, please email us at

Part 1- The trainer and assessor files

Compliance of your trainer records is a must for any Registered Training Organisation. If you do not know what you are looking for, you will always have difficulty finding it. The purpose of this article is to provide you with the required information and resources to ensure you can audit and review your trainer and assessor files to be compliant with the current regulatory requirements and standards.

Legislative and regulatory requirements:
Trainers and assessors must comply with the following SRTOs 2015 requirements:

  • Clauses 1.13 – 1.16
  • Trainers and assessors who deliver any Australian Qualifications Framework (AQF) qualification or skill set from the Training and Education Training Package (TAE10, TAE or its successor) are also required to meet additional requirements, outlined in Clauses 1.21 – 1.24.

Requirements for all trainers and assessors:
Trainers and assessors must meet the following criteria and guidelines:

  • the vocational competencies at least to the level being delivered and assessed
  • current industry skills directly relevant to the training and assessment being provided, and
  • current knowledge and skills in vocational training and learning that informs their training and assessment.

In addition, training and assessment may only be delivered by persons who have:

  • Certificate IV in Training and Assessment (TAE40110 or TAE40116), or its successor*, or
  • A diploma or higher level qualification in adult education.

Your RTO must also ensure that all trainers and assessors undertake professional development in the fields of:

  • knowledge and practice of vocational training, and
  • learning and assessment, including competency-based training and assessment.

Trainer’s CV
An RTO must hold valid files for all Trainers and Assessors (this includes files for contractors and employees). A valid file includes the following information:

  • A current copy of the trainer/assessor’s CV (usually updated on an annual basis)
  • The RTO’s name, the position title and a description of the job-role
  • Details about the vocational competencies that the trainer/assessor holds
  • Details about the vocational competencies that the trainer/assessor is delivering/assessing.
  • Information about industry currency and skills
  • List of VET professional development activities
  • Confirmation that it is a true and up-to-date copy of the CV (usually means the trainer/assessor initialling each page of the CV to confirm the accuracy of the information provided)
  • Signature and date of last update of the CV

It is also recommended that all resumes/CVs are verified for currency and authenticity through the undertaking of reference checks.

Fact sheet—Meeting trainer and assessor requirements, published by ASQA

(To be continued in the upcoming newsletter and blogs)

Part 1- The importance of internal audits

This is our first article in the series regarding “Internal audits”. Our main intention is to provide you with the required knowledge and skills, and equip you with the necessary resources to ensure you can audit your organisation against quality frameworks and standards effectively and efficiently.

What are Internal audits?
Internal audits are an independent, collaborative, impartial, objective assurance and consulting activity formulated to add value and improve operations of an organisation. It assists the organisation to bring a systematic, disciplined approach to effectively evaluate, monitor and improve the effectiveness of risk management, internal control and governance processes. Internal audits act as a catalyst for a strong risk and compliance culture within an organisation.

What are the benefits of conducting internal audits?
Internal audits act as a catalyst for enhancing an organisation’s governance, risk management and controls by presenting insight and recommendations based on interpretation and examination of data and business practices and processes. There are a number of other benefits, such as:

  • Audits assess an organisation’s performance and practices against the regulatory framework, guidelines and legislative/statutory instruments.
  • Audits provide management of an organisation with information on the effectiveness of risk management, control and governance processes.
  • Audits evaluate achievement of organisation objectives
  • Audits ensure assets are safeguarded and secure.
  • Audits assess efficiency, effectiveness and the economy of business activities.
  • Audits review operations and processes to ensure they are protected from any fraud, malpractice or corruption
  • Audits increase financial reliability and integrity
  • Audits help to improve the “control environment” of the organisation
  • Audits are great learning lessons for all parties involved
  • Audits identify the business areas that require urgent attention
  • Audits identify opportunities, accountabilities and risks
  • Audits help management understand what it needs to know, when it needs to know it and how it needs to be done or implemented.
  • Audits identify better ways of doing things by recommending how to improve internal controls and governance processes

What is an audit scope?
The scope of audit refers to the focus, extent, boundaries and range of the activities covered by an internal audit. It includes:

  • The objectives for conducting an audit
  • Nature and extent of auditing procedures and activities performed
  • The organisational units that will be examined
  • Location of the audit
  • Time-period that will be covered
  • Related activities not audited in order to define the boundaries of the audit.

The audit scope, ultimately, establishes how deeply an audit is required to be performed.

What is usually included in an RTO internal audit?
The internal audit is usually a documented process that includes the evaluation of the following:

  • Quality framework and standards and legislative guidelines
  • Training packages and the companion volume (including the implementation guides)
  • Assessment and learner resources
  • Training and assessment strategies
  • Trainers and assessors
  • Industry consultation and engagement and how improvements are made from them
  • Recognition of prior learning and credit-transfers
  • Transitioning planning, processes and procedures
  • Student certification and completion processes and procedures
  • Third-party agreements and monitoring processes and procedures
  • Student support, progression and welfare processes and procedures
  • Student and staff Interviews and questionnaires
  • Student records, student files and student data analysis
  • Enrolment and pre-enrolment processes and procedures
  • Marketing and advertising practices and procedures
  • Regulatory compliance and governance practice
  • Policies and procedures an organisation uses
  • Other organisational practices and systems

Who can be an internal auditor?
An Internal auditor can be anyone who has the required knowledge, skills and experience to objectively, professionally and unbiasedly evaluate your organisation’s processes and procedures to identify opportunities for improvements.

It can be an internal staff member or an external person such as a compliance consultant.

The required knowledge, skills and experience of internal auditors will be discussed in our next edition.

(To be continued in the upcoming newsletter and blogs)

Various phases of the assessment and validation processes (Part 3)

This is Part 3 of the article, where we are discussing the different phases of the validation processes an RTO should be following to ensure they meet regulatory requirements and industry expectations.

In the previous articles, we discussed the following regarding the validation of assessment resources:

  • Explanation of assessment validation
  • Typical benchmarks used during the validation processes
  • Stages of validation (before, during and after the assessment judgements)
  • Regulatory requirements for conducting validation
  • Assessment system
  • Who conducts validation?
  • How is validation different from moderation?
  • How external consultants can help you with validation of assessment and learner resources?

In this month’s article, we will explore the regulatory requirements around validation of learner resources.

Learner resources
Learner resources are also known as “learning resources”, “training resources”, or “companion guides”. The purpose of these resources is to support learners with the underpinning knowledge required to participate in skill-based tasks. These resources include a range of activities to support the learning including, formative assessments and activities, links to further reading, workplace activities and procedures (where relevant to the qualification) etc.

Why you need to validate your learner resources
The VET regulator, ASQA does not currently prescribe the methodology Registered Training Organisations (RTOs) should use to meet the requirements of the relevant standards, training packages and accredited courses for learner resources.

But their expectations under the Standards for Registered Training Organisations, 2015, is to ensure your learner resources meet the following legislative guidelines:

Standard 1, Clause 1.3 (c): Learning resources to enable learners to meet the requirements for each unit of competency, and which are accessible to the learner regardless of location or mode of delivery.

The guidelines further state that:

Learning resources

  • To ensure students are able to obtain and absorb the required knowledge and skills prior to assessment, carefully choose and plan the learning resources you will use to guide them.
  • Identify these resources in your strategy to ensure you obtain full coverage of all required areas.

Therefore, we strongly recommend validating your learner resources to ensure your organisation complies with the relevant legislative requirements and guidelines.

The process of validation of learner resources
The validation of learner resources is not very different from the validation of assessment resources. All learner resources must also meet training package requirements and industry expectations.

Who can be involved in validating the learner resources
There are currently no regulatory requirements around who can participate in the validation of learner resources, however, it should be no different from the validation of assessment resources.

It should be a collective team effort and you must include the following people to validate your learner resources:

  • Subject matter experts
  • Trainers and assessors
  • Compliance or administration manager
  • Industry experts
  • You may also include compliance experts as well as they usually have current and up-to-date knowledge around audit and compliance expectations and requirements.

Stages of validation for learner resources
Stage 1: Validation before using the learner resources
Validation before using the learner resources is to ensure the resources meet training package requirements, how the information is presented and the quality of the formative assessments. This is to ensure the student gains the required skills and knowledge to participate in the summative assessments later. Your review of the learner resources templates in detail ensures they are compliant and meet regulatory standards and Industry requirements.

Stage 2: Validation during or after using the learner resources
Your validation of learner resources during or after use is to ensure:

  • Your resources meet client expectations
  • Your resources meet training package guidelines and provide all required underpinning knowledge to your students
  • Your resources are current and up-to-date in terms of the latest trends, technology and industry guidelines and practices.

In the next and final article, we will discuss:

  • Why you need to keep validators information
  • Why validation of assessment and learner resources should be systematic and ongoing
  • How can you schedule validation
  • What is statistically valid sampling
  • Validation outcomes

(To be continued in the upcoming newsletter and blogs)

Assessment issues that may have an impact on your RTO audit (Part 2)

This is Part 2 continuing from the previous newsletter. As discussed in Part 1 of this article, there are a number of assessment-related issues that may affect your audit outcome. You should ensure your assessment resources, therefore, meet the following criteria:

  • The context and conditions of assessment. For example, an assessment tool could be developed to cater for a particular language, literacy and numeracy requirements, the learner’s workplace experience or other learner needs that require reasonable adjustment.
  • The context of the assessment may also take into account assessments already completed, and the competencies demonstrated in these assessments. By looking at the context, you can consider the conditions under which evidence for assessment must be gathered.
  • All activities are conducted adequately using the required:
    • equipment or material requirements
    • contingencies
    • specifications
    • physical conditions
    • relationships with team members and supervisors
    • relationships with clients/customers
    • timeframes for completion.
  • Assessment methods or tasks are suitable to the requirements of the units of competency and students are assessed on the tasks and activities according to the requirements of the training package.
  • The language used is simple English
  • The evidence required to make a decision of competency is clearly outlined
  • The types of activities and tasks student need to perform are clearly outlined
  • The level of performance required for each assessment activity is clearly outlined
  • Adequate exposure to workplace conditions, including appropriate simulated environments
  • Sufficient knowledge-based assessment tasks and activities such as written questions and case studies etc.
  • Sufficient practical based assessment tasks and activities such as projects, role plays, workplace tasks and observations etc.
  • Assessment resources are error-free and free from any grammar, copyright or plagiarism issues

It is a wise decision to get your training and assessment strategies and resources validated by independent industry experts to get honest feedback and an unbiased opinion.

Various phases of the assessment and validation processes (Part 2)

This is Part 2 of the article, where we are discussing the different phases of the validation processes an RTO should be following to ensure you meet regulatory requirements and industry expectations.

In the previous article, we discussed the following regarding the validation of assessment resources:

  • Explanation of assessment validation
  • Typical benchmarks used during the validation processes
  • Stages of validation (before, during and after the assessment judgements)

In this month’s article, we will explore the regulatory requirements around assessment validation.

Regulatory requirements for conducting validation

According to the Standards of Registered Training Organisations (RTOs) 2015, you are required to implement a quality review process (Clauses 1.8, 1.9, 1.10 and 1.11).

Clause 1.8a requires that the RTO’s assessment systems comply with the assessment requirements of the relevant training packages or VET accredited courses.  

Clause 1.8b requires RTOs to ensure that the evidence gathered is valid (one of the Rules of Evidence) and that assessment processes and outcomes are valid (one of the Principles of Assessment). 

These requirements must be met and demonstrated in all assessment policies, procedures, materials and tools of the RTO. Clause 1.8 primarily relates to the development (or purchase) of the RTO’s assessment resources.

Assessment validation has been strengthened in the Standards for RTOs and the requirement is to:

  • Develop and implement a comprehensive plan for ongoing systematic validation of assessment that includes all training products on the RTO’s scope of delivery (Clause 1.9)
  • Validate the assessment practices and judgements for each training product at least once every five years with at least 50% of products to be validated within the first three years of each five-year cycle (Clause 1.10)
  • Ensure that validation is conducted by one or more suitably qualified persons, who are not directly involved in the delivery and/or assessment of the training product being validated. (Clause 1.11).
  • These clauses relate primarily to the actual delivery and outcomes of the RTO’s assessment systems, including the performance of the RTO’s assessors.

Assessment system

Documents required for conducting an effective validation session, in the RTO’s assessment system, includes but is not limited to:

Validation related documents:

  • Validation plan
  • Validation schedule
  • Validation record or validation form
  • Validation register
  • Validation report form
  • Continuous improvement form
  • Continuous improvement register
  • Pre-assessment validation documents

Assessment resources:

  • Unit assessment pack/student pack
  • Trainer assessment pack/assessor pack
  • Mapping document
  • Assessment evidence according to a sample size

Other documents:

  • Training and assessment strategy
  • Feedback forms
  • Unit of competency
  • Companion volume/implementation guide
  • AQF framework
  • ACSF framework

You will be required to evaluate if the assessment resources meet:

  • Training package requirements (application, elements and performance criteria, foundation skills, performance evidence, knowledge evidence, assessment conditions)
  • Principles of assessment; fairness, flexibility, validity and reliability
  • Rules of evidence; valid, sufficient, authentic and current
  • The appropriate level of difficulties (AQF Level)
  • Provide sufficient and clear instructions
  • Record any appropriate adjustments

Who conducts validation?

Validation is a collaborative process. The team must hold collectively:

  • Vocational competencies and current industry skills relevant to the assessment being validated
  • Current knowledge and skills in vocational teaching and learning
  • The TAE40110 Certificate IV in Training and Assessment (or its successor) or the TAESS00001 Assessor Skills Set (or its successor).
  • Validators can be employees of your RTO, or you can seek external validators.

The trainer and assessor who delivered/assessed the training product being validated:

  • Can participate in the validation process as part of a team
  • Cannot conduct the validation on his/her own
  • Cannot determine the validation outcome for any assessment judgements they made
  • Cannot be the lead validator in the assessment team.

It is important to keep the records of all validation activities and validators as auditors might ask for it during audit activities and for managing continuous improvement processes at an RTO.

How is validation different from moderation?

Moderation is a quality control process aimed at bringing assessment judgements into alignment.

Moderation is generally conducted before the finalisation of student results as it ensures the same decisions are applied to all assessment results within the same unit of competency.

The requirement in the Standards to undertake validation of assessment judgements does not affect your RTO’s ability to undertake moderation activities, or any other process aimed at increasing the quality of assessment.

(ASQA, 2018)

(To be continued in the next newsletter)

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

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)

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 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 

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

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 


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

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


Annual declaration on compliance

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.
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 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
You can read more about validation schedule and conducting validation at
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)

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
Maybe ASQA’s auditors can shed some light on these new requirements?

Unpacking ASQA audit reports and files (Part 3)

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)

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

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

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? 


  • 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.