Different phases of assessment and learner 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 training.gov.au website.
  • Units of competency which consist of competency standards and need to be unpacked so that those validating the assessments can compare the actual competency against the tools being validated.
  • Industry standards and consultation will vary, and these standards form the basis of the skills and knowledge required to perform work roles.
  • AQF Guidelines and Framework
  • Information provided to candidates, assessors and third parties
  • Legislation relevant to the assessment such as privacy, health and safety, anti-discrimination, copyright law and so on.

Validation occurs through different stages:

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

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

Stage 2: Validation during assessment

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

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

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

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

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

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

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

(To be continued in the upcoming blogs) 

Assessment issues that may impact 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 

Heavy penalty for bogus qualification

A former trainer has been ordered to pay $120,000 for providing her employer with 11 bogus vocational education and training (VET) qualifications, providing another two bogus qualifications to a co-worker and submitting false qualifications to the national regulator as proof of her competency.

The Australian Skills Quality Authority (ASQA) successfully obtained declarations from the Federal Court that Synthia Dee M Restar of Beecroft, New South Wales, fabricated the qualifications in contravention of the National Vocational Education and Training Regulator Act 2011.

Between January 2012 and April 2014, Ms Restar fabricated qualifications in aged care, disability and business management in her own name and provided each to her employer as legitimate qualifications. She also provided three of the bogus qualifications to an ASQA auditor in support of an application to become a registered training organisation (RTO).

Ms Restar also fabricated two aged care qualifications for a co-worker and falsely represented those qualifications to be legitimate.

ASQA Chief Commissioner Chris Robinson said the bogus qualifications were uncovered during an ASQA investigation.

“As a result of this investigation, ASQA cancelled the registration of the RTO in question and used the powers available to it to pursue Ms Restar for her wrongdoing,” Mr Robinson said.

Mr Robinson said ASQA had been building its investigative capabilities during the past 18 months.

ASQA is determined to use the powers available to it to ensure learners are getting high quality training and assessment which provides them with the skills that employers are looking for.

The authority has close to 100 officers – including many with specialist investigative skills and experience – who are applying regulatory scrutiny to RTOs across Australia each and every day.

“ASQA will continue to target its resources at RTOs providing poor quality training and seek to remove them from the sector and, where appropriate, seek criminal or civil prosecutions.”

For more Information, visit ASQA’s website: http://www.asqa.gov.au/news/3083/heavy-penalty-for-bogus-qualification.html

‘Unscrupulous training providers’ to be investigated

The Andrews Labor Government is upping the pressure on rogue training providers with a new investigations unit in the Department of Education and Training to put them under the microscope.

Dodgy training courses in Victoria will soon be scrutinised by a new investigation led by a former Victorian Ombudsman investigator.

The crack squad, headed by a former Victorian Ombudsman Principal Investigator, will conduct targeted and more detailed investigations into unscrupulous training providers to restore student and industry confidence to the sector.

The team will add to the Department’s capability to expose poor quality providers to ensure qualifications are meeting industry standards and making sure students are receiving the skills they need to do their job safely.

The new team is the latest initiative as part of the Labor Government’s crackdown on unscrupulous training providers to restore student and employer confidence in the training system. It will examine:

  • Inappropriate low quality short course delivery

  • The quality of the course delivery from training providers

  • The suitability of a qualification for students and whether it leads to a job

  • The marketing practices of training providers

  • Suspected fraud and refer to relevant authorities

Since the Labor Government’s quality blitz started in July 2015, 57 RTOs have been identified for investigation, 15 training contracts have been terminated and $40 million in Victorian taxpayer’s money earmarked for recovery.

The 2015 Training Market Report has revealed training providers who had their contract cancelled or who did not receive a 2016 contract, accounted for half of the total decline in course enrolments last year.

Quotes attributable to Minister for Training and Skills Steve Herbert

“We’re leading the country with stamping out rogue training providers. We’re working to restore confidence to the system prior to the introduction of a new funding system in 2017.”

“We will not give providers a blank cheque for taxpayers’ money – especially when the safety of the community could be put at risk because of substandard training.”

“Our new tough contracts and tougher entry requirements for RTOs accessing government funded training mean students can have confidence in the training they’re receiving.”

References: http://www.premier.vic.gov.au/

ASQA News 14-Aug-2018

ASQA given additional powers to seek civil penalties and issue infringement notices 

On 12 July 2018, the Governor-General, Sir Peter Cosgrove AK MC made the National Vocational Education and Training Regulator Amendment (Enforcement and Other Measures) Regulations 2018(NVR Regulation Amendment 2018).

The NVR Regulation Amendment 2018 allows ASQA to seek civil penalties for breaches of the Standards for Registered Training Organisations (the Standards), even in cases where a provider has since rectified that breach.

This legislative change enhances ASQA’s capacity to effectively support the quality of the VET sector by providing an additional mechanism to protect students from poor-quality providers.

ELICOS course template now available 

The Australian Skills Quality Authority (ASQA) has developed a course proposal template for use by providers applying to register English Language Intensive Courses for Overseas Students (ELICOS) on the Commonwealth Register for Institutions and Courses for Overseas Students (CRICOS).

ASQA has developed this template in response to feedback from providers seeking guidance and a consistent format for providing evidence to demonstrate compliance against ‘Standard C1—Mandatory requirements for course applications’ of the ELICOS Standards 2018.

The use of this template is strongly recommended but not mandatory.

Cancellation of registration as a provider of vocational education and training (VET) services:

Rejection of application to renew registration as a provider of VET services:

Extension to transition period for Advanced Diploma, Diploma of Accounting qualifications

The Australian Skills Quality Authority (ASQA) has approved an extension to the transition period for the FNS50215 Diploma of Accounting and FNS60215 Advanced Diploma of Accounting.

The qualifications were superseded in February 2018 by the FNS50217 Diploma of Accounting and FNS60217 Advanced Diploma of Accounting, which are not equivalent. As a result, current learners were initially given until 12 February 2019 to complete their training and assessment.

However, learners transitioning to the replacement qualifications must meet additional entry requirements. This would genuinely disadvantage any learners in the superseded qualifications who are unable to complete the qualifications by 12 February 2019.

As such, ASQA has agreed to an extended training, assessment and certification issuance period for these qualifications, which will end on 12 February 2020.

For more information, please visit ASQA’s websitehttps://www.asqa.gov.au/news-publications/news

The Difference Between Compliance and Quality Assurance in the RTO space (Part 2)

When we look at the current Standards for Registered Training Organisations 2015, the clauses relevant to Registered Training Organisations’ regulatory compliance, the reporting and governance practice, they all clearly underpin good management practices and effective compliance control procedures—and, as a result, the effective functioning and sustainability of RTOs.

These Standards support RTOs to provide high-quality student experiences and learning outcomes.

Under the Standards, RTOs are responsible for:

  • Ensuring authorised Executive Officers and High Managerial Agents meet the Fit and Proper Person requirements and are vested with sufficient authority to ensure the RTO complies with the RTO Standards at all times (clause 7.1)
  • Satisfying financial viability risk assessment: Your RTO is required to present an acceptable level of financial viability risk at all times (this includes any parent entities). ASQA assesses each RTO’s financial viability risk to evaluate the likelihood of business continuity and the RTO’s capacity to achieve quality outcomes, as outlined in the Financial Viability Risk Assessment Requirements 2011. ASQA considers this against the potential for adverse consequences if your entity collapses or becomes unviable and makes a judgement about whether the level of risk is acceptable, unacceptable, or requires additional controls. To enable a preliminary financial viability risk assessment, the initial registration application requires the applicant to provide:
    • a range of financial sustainability information
    • independent certification.

ASQA may also require your RTO to undergo a financial viability risk assessment at any other time. (clause 7.2)

  • Compliance and reporting: The RTO must make sure it complies with the SRTO’s 2015, other Commonwealth, State and Territory legislation and regulatory requirements relevant to its operations, at all times, including where services are being delivered on its behalf. The RTO is required to provide an annual declaration on compliance to confirm whether it:
    1. currently meets the requirements of the Standards across all its scope of registration and has met the requirements of the Standards for all AQF [Australian Qualifications Framework] certification documentation it has issued in the previous 12 months.
    2. has training and assessment strategies and practices in place that ensure that all current and prospective learners will be trained and assessed in accordance with the requirements of the Standards.

RTOs are also required to make sure its staff and clients are informed of any changes to legislative and regulatory requirements that affect the services delivered. (clauses 2.1 and 8.4 to 8.6)

  • Recording, monitoring and reporting third-party arrangements: All third-party arrangements must have a written agreement, the RTO must have sufficient strategies and resources to systematically monitor any services delivered on its behalf, and notifies the Regulator:
  1. of any written agreement entered into under clause 2.3 for the delivery of services on its behalf within 30 calendar days of that agreement being entered into or prior to the obligations under the agreement taking effect, whichever occurs first, and
  2. within 30 calendar days of the agreement coming to an end.  (clauses 2.3, 2.4 and 8.3)
  • Holding public liability insurance: RTOs are responsible for ensuring they hold public liability insurance throughout their registration period. Your RTO must hold public liability insurance to cover all training and/or assessment activities it provides as an RTO. (clause 7.4)
  • Meeting Data Provision Requirements:

RTOs are responsible for providing accurate information about their performance and governance in accordance with clause 7.5.

The Data Provision Requirements outline information that your RTO is required to submit. Apart from information required with applications, this falls generally into two categories:

Australian Vocational Education and Training Management Information Statistical Standard (AVETMISS) data

Quality Indicator Data.

Data such as national training activity is very important—this informs decision-making about policies and funding for the national VET system and allows measurement of the system’s performance.

The quality indicator data provides information for RTOs about their students’ experiences of their services and can be used to continuously improve the quality of the training for students and employers. (clause 7.5)

Providing requested information to ASQA:

RTOs are responsible for:

  • Cooperating with ASQA
  • Ensuring any third party delivering services on the RTO’s behalf is required to cooperate with ASQA.

Your RTO and any third parties delivering services on your behalf must cooperate with ASQA in responding to requests for information, undergoing audits and managing records. The information you and third parties provide to ASQA must be accurate, truthful and authentic. Any documentation provided at audit must be an accurate representation of your RTO’s practices.

You must notify ASQA within 90 days of the following:

  • Changes to executive officers or high managerial agents
  • Changes to financial administration status (e.g. liquidators being appointed)
  • Changes to legal name or type of legal entity
  • Changes to ownership, directorship or control (including changes to parent entities)
  • Significant mergers or associations with other RTOs
  • Registration (or application) with other education regulators (e.g. higher education provider with the Tertiary Education Quality Standards Agency)
  • Anything that may affect the fit and proper person status of an influential representative of the RTO
  • Changes to any fundamental funding/revenue source (e.g. access to or loss of government funding contract allocation)
  • Changes to the RTO’s business strategy (e.g. more to online delivery, assessment-only delivery, offshore delivery)
  • Delivery to apprentices or trainees employed under a training contract
  • Any other significant event.

(clauses 8.1 and 8.2).

In the next post we will look into the “quality assurance” requirements and obligations for your RTO.

To be continued…

The Difference Between Compliance And Quality Assurance in the RTO space

When you plan to run a registered training organisation (RTO), you may find it difficult to know:

  • the complete regulatory framework and environment 
  • your legal obligations and
  • everything else required to run a successful, compliant Registered Training Organisation.

Take compliance and quality assurance, for example, you may have heard about them, but do you know what they mean?

What is compliance?

Numerous legislation, regulations and guidelines in Australia regulate the way we run an RTO such as:

  • Australian Consumer Law (ACL),
  • the Racial Discrimination Act 1975,
  • the Sex Discrimination Act 1984,
  • the Disability Discrimination Act 1992,
  • the Age Discrimination Act 2004,
  • the Child Protection Act 1999,
  • the Work Health and Safety Act 2011,
  • the Australian Human Rights Commission Act 1986,
  • the Privacy Act 1988 and
  • the National Vocational Education and Training Regulator Act 2011. 

This is not an exhaustive list. These legislation, regulations and guidelines specify the framework and the obligations to operate an RTO.

A number of these obligations are applicable on all business entities that operates within Australia and are overseen by the Australian Securities and Investments Commission (ASIC).

The law does not allow you to be an officeholder or manage a company (without court consent) if:

  • you are currently bankrupt
  • you are still subject to a personal insolvency agreement or composition under the Bankruptcy Act 1966, or
  • have been convicted of offences like fraud or breaching your duties as an officeholder.

If you are member of ACPET or other industry bodies, they may also have codes of conduct and specific guidelines that you must follow to continue to be a member. These requirements and obligations come under “compliance”. Failing to meet all state and federal guidelines for compliance can result in serious consequences for your registered training organisation (RTO). Along with altering your company’s legal status, which may leave you vulnerable to lawsuits, government agencies may conduct audits, enact fines or even dissolve your business entirely. 

What is quality assurance?

Standard 2 of the SRTOs 2015 (Standards for Registered Training Organisations, 2015) states that the operations of the RTO must be quality assured. Quality assurance refers to “meeting and delivering intended performance according to certain benchmarking standards”.

Let’s look at Standard 2:  Clause 2.1 – 2.4

2.1 The RTO ensures it complies with these Standards at all times, including where services are being delivered on its behalf. This applies to all operations of and RTO within its scope of registration. 

2.2 The RTO:

  • Systematically monitors the RTO’s training and assessment strategies and practices to ensure ongoing compliance with Standard 1; and
  • Systematically evaluates and uses outcomes of the evaluation to continually improve the RTO’s training and assessment strategies and practices. Evaluation information includes but is not limited to quality/performance indicator data collected under Clause 7.5, validation outcomes, client, trainer and assessor feedback and complaints and appeals.

2.3 The RTO ensures that where services are provided on its behalf by a third party the provision of those services is the subject of a written agreement. 

2.4 The RTO has sufficient strategies and resources to systematically monitor any services delivered on its behalf, and uses these to ensure that the services delivered comply with these Standards at all times

While Standard 2 of SRTOs 2015 addresses the key client criteria of quality training and assessment strategies and practices there are many other quality considerations that make up a quality-assured RTO business.
Every RTO must have a system (often referred to as a ‘business or quality management system’) to manage its operations. The system should provide the basis for quality assuring a business.

Quality assurance is maintained by ensuring that:

  • The organisation understands the relationship and differences between Quality Management systems, Quality standards and Regulatory standards.
  • Understand how a properly implemented business (quality) management system can help improve fundamental business performance well beyond just meeting compliance/regulatory requirements
  • Use quality assurance techniques to help review their existing system and processes
  • Revitalise their existing quality management system
  • Organisation participate in professional networking with colleagues across RTOs and wider industry.

To be continued…

ASQA News 12-Jul-2018

Definition of Enterprise RTOs updated

ASQA has recently updated their guide for the Application of Initial Registration with changes taking effect as of the 1st of July, 2018.  You can find this and download for your own reference here:
https://www.asqa.gov.au/sites/g/files/net3521/f/application_guide_-_application_for_initial_registration.pdf?v=1525230496

Once of the changes noted, has been to the definition of an Enterprise RTO.  ASQA now deem an Enterprise RTO to be:
 
“An enterprise or the training function or department of an enterprise that is registered to provide nationally recognised training. Training is delivered only to its employees. 

This includes, for example: 

Enterprise—government (for example, Department of Defence) 
Enterprise—non-government (for example, Woolworths, Qantas)”

Issuance of false qualifications leads to $31,400 penalty
A Queensland man who misled three individuals into providing payment for false qualifications has been ordered to pay a pecuniary penalty of $31,400.

On 5 July 2018, the Australian Skills Quality Authority (ASQA) successfully obtained a declaration from the Federal Court that Scott Andrew Jones created false qualifications concerning “Engineering—Fabrication Trade”, in the names of three different people, and provided those documents for a fee.
 
The court found that Mr Jones falsely represented to these individuals that each qualification was a legitimate vocational education and training (VET) qualification issued by a registered training organisation (RTO).
 
ASQA Chief Commissioner Mark Paterson said ASQA began investigating Mr Jones following a complaint.
 
“The investigation identified that Mr Jones had offered to assist work colleagues by enrolling them with TAFE Queensland to seek recognition of prior learning for engineering qualifications. Mr Jones took money from these individuals and then copied a legitimate qualification in order to issue documentation, which he purported to be from TAFE Queensland, to his colleagues. 
 

As a result of its investigation, ASQA commenced a civil prosecution against Mr Jones.

Read more

Reporting obligations for Registered Training Organisations

Under the Standards for Registered Training Organisations 2015, all RTOs are obliged to provide accurate and complete data. 
 

All ASQA-registered training organisations RTO must meet mandatory annual data submission requirements, including:

  • Submitting the annual declaration on compliance to ASQA
  • Submitting total VET activity (TVA) data, including the reporting of unique student identifier (USI) data.

There is a limited number of exemptions for some short courses and eligible RTOs, however, if you are delivering training under a funding agreement you are required to report all of your contracted delivery to the relevant Department. 
 

Organisations are, therefore, responsible for a number of reporting requirements under the Standards for Registered Training Organisations 2015. The reporting requirements include:

The annual declaration on compliance

The Standards require each RTO to provide ASQA with an annual declaration on their RTO’s compliance.
The annual declaration must be signed by the principal executive officer/chief executive officer registered with ASQA as listed on training.gov.au.  


If you are the RTO CEO or PEO, ASQA will notify you by email of your obligation to complete the declaration and provide you with a link to the online form. You can check your details on training.gov.au to ensure that ASQA has access to your current email address to ensure you receive this invitation.


When you submit the declaration, you are confirming to ASQA that you:

  • Systematically monitor your RTO’s compliance
  • Implement preventive and corrective actions where considered necessary.

The declaration also asks you to confirm that records pertaining to your RTO, as reflected on training.gov.au, are accurate and up to date.

 

Reporting requirement: Total VET Activity (AVETMISS and USI) 

The Australian Vocational Education Training Management Information Statistical Standard (AVETMISS) for VET Providers is a national data standard that ensures the consistent and accurate capture of VET information about students, their courses, units of activity, and qualifications completed. It provides the mechanism for national reporting of VET activity. 


Provides information through NCVER to Industry stakeholders about: 

  • Statistical information captured for national reporting 
  • Unique Student Identifier and all award issuance activity conducted in the previous year

Reporting requirement: Quality Indicators 

These include learner and employer survey data to collect evidence-based and outcome-focussed continuous quality improvement, and assist the VET Regulator to assess the risk of an RTO’s operations:

Other information you must submit:

You must collect AVETMISS-compliant records for all students, and for all competency enrolments and outcomes achieved, throughout the calendar year.

Early in the following year, you must report this data to the National Centre for Vocational Education Research (NCVER) unless you have previously done so through existing contractual arrangements.

RTOs should refer to NCVER’s publications AVETMISS 7.0 VET Provider Collection Specifications and AVETMISS data element definitions which describe the AVETMISS data to be collected.

There are a number of student management systems that can record and produce AVETMISS data files for reporting. A register of data entry tools and student management systems is available on the NCVER website.

NCVER has developed a free AVETMISS data entry tool for RTOs with less than 100 students and an AVETMISS validation software for RTOs to validate their data before submission. Both tools are available on the NCVER website.

For further information, and a range of fact sheets, about Total VET Activity data, please see the:

Visit ASQA website for more information  https://www.asqa.gov.au/vet-registration/meet-data-provision-requirements

Contextualising assessment resources (Part 2)

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.

How to contextualise units of competency?

Contextualisation is a process that we use to create learning/assessment opportunities that are more relevant to our learner. When we do this, we link the Unit of Competency to the client’s needs using language that they understand.

Contextualisation is achieved by including, modifying or substituting text within units of competency and usually within the assessment requirements including performance evidence, knowledge evidence and assessment conditions.

It is about providing training and assessment that is specific to an enterprise or individual learner.

Any modifications to a unit of competency must maintain the integrity of the industry skill and portability requirements, including all legislative licensing and any other regulatory requirements.

The following are some suggestions for contextualising units of competency to make them more relevant for specific industries or workplaces:

  • Refer to the guidelines in the relevant training package. Usually, it will be possible to replace generic terms and general descriptions of equipment or processes and procedures with specific examples. For example, a guide working at Uluru may learn and demonstrate body language appropriate to the Pitjantjatjara people. There would be little point in that guide being required to learn and demonstrate body language appropriate for working among the Jewish community at the Sydney Holocaust Museum.
  • Analyse the generalised statements about the range of work and job tasks specified in the units of competency. These may need to be aligned to a particular job profile and translated to highlight particular tasks and levels of performance that are relevant to a particular workplace.
  • Identify the kinds of evidence that candidates may be able to provide in their job roles to satisfy the requirements of a particular unit of competency.
  • Prepare evidence plans for the candidates, showing how they might collect the identified kinds of evidence.

Let’s have a look at some examples:

  • If the Competency mentions Machinery, then we could use the exact name of the machine used.
  • If the Competency mentions Equipment, then we could use the names of each item of equipment
  • If the Competency mentions Location, then we could use the exact location, eg, Shed 1, kitchen bench, etc
  • If the Competency mentions Relevant Procedures, then we could use the exact title of the procedure manual
  • If the Competency mentions Relevant Personnel, then we could use the names of the people and their positions

Contextualise, but Follow the Rules

When it comes to contextualisation, we can be very creative. But, we need to make sure that we do not change the standards required of us. Remember: we must always follow the Qualification Packaging Rules of the Training Package.

When contextualising units of competency, teachers and trainers:

  • Must not remove the number and content of elements and performance criteria
  • May add specific industry terminology to performance criteria where this does not distort or narrow the competency outcomes
  • Changes should not diminish the breadth of application of the competency and reduce its portability
  • May add detail to the assessment requirements, where these expand the breadth of the competency but do not limit its use.

To make sure that we still follow the Training Package rules, we can read the Training Package itself, or we can get the advice of others, including:

  • Skills Service Organisations (SSOs) and Industry Reference Committees (IRCs) responsible
  • Our colleagues within the training industry or within the industry for whom we are delivering the training
  • Accessing the Support Resources available for each Training Package at TGA (training.gov.au) can also give us some great ideas of what is appropriate.

When we are contextualising, it is a good idea to speak with the client to make sure that we really are going to link the Unit of Competency to the participants’ actual work.

When we are contextualising, it is a good idea to speak with others to make sure that we really are going to be delivering the Unit of Competency in accordance with the Training Package rules.

Time to submit your "Quality Indicator data" to ASQA

What are the “Quality Indicators”?

RTOs are required to collect and report their performance against the following quality indicators:

  1. Learner engagement
  2. Employer satisfaction

Learner engagement 

This quality indicator focuses on the extent to which learners engage in activities that are likely to promote high-quality skill outcomes. It includes learner perceptions of the quality of their competency development and the support they receive from their RTOs. The source of data to measure this indicator is a survey called the Learner Questionnaire. RTOs must gather and analyse this data each year.

Employer satisfaction 

This quality indicator focuses on employer evaluation of learner competency development and the relevance of learner competencies for work and further training, as well as employer evaluation of the overall quality of the training and assessment. The source of data to measure this indicator is a survey called the Employer Questionnaire.

RTO’s must gather and analyse this data each year and submit on or before 30 June.


Why are “Quality Indicators” required?

The Quality Indicators give an overall picture of the outcomes being achieved by the RTO and how well it is meeting client needs. Information about the quality of training being provided by an RTO is relevant to a wide range stakeholders. The key audiences are the RTO’s management and their Registering Body. Other audiences may include learners, employers, senior management, individual staff members and potential learners and employers.

The QI’s provide valuable information that the RTO can use to assess their performance against the SRTOs 2015. The data can contribute to evidence that:

  • The RTO provides quality training and assessment across all of its operations
  • The RTO adheres to principles of access and equity and maximises outcomes for its clients
  • Management systems are responsive to the needs of clients, staff and stakeholders, and the environment in which the RTO operates
  • Quality can be monitored over time to identify both improvements and any downward trends.

Learner and employer survey results provide RTO’s with a basis for undertaking benchmarking activities with other RTO’s, or to compare different respondent groups, if they decide to do this as part of their continuous improvement processes.

Learner and employer survey data can be used to demonstrate the quality of the RTO’s training operations, and to build confidence in the RTO.


What is best practice regarding the “Quality Indicators”?
 

A targeted student should be provided with a “Learner Questionnaire” and an employer with “Employer Questionnaire”. The data should be then collected and analysed using:

  • Survey Management, Analysis and Reporting Tool (no longer available for download) or
  • ASQA’s Quality Indicator annual summary report template (DOC).

This information should be submitted to ASQA prior to 30th June annually. 

The surveys should be validated to ensure the student /client feedback is addressed and the RTO provides continuous improvement to develop better learning and learning outcomes.

The resulting changes should be documented and feedback should be communicated to the relevant committee/panel/member of the organisation.

The changes should also be documented in the RTO’s Continuous Improvement Register.

For more information, Click Here.

What happens when things have not been resolved and you have to take your matter to the Administrative Appeals Tribunal?

The Administrative Appeals Tribunal (AAT) provides an independent review of a wide range of administrative decisions made by the Australian Government (and some non-government bodies). The AAT aims to provide fair, impartial, high quality and prompt review with as little formality and technicality as possible.

How do I lodge an application for review?

Your application to the AAT must be lodged:

  1. in writing (using the forms available from the AAT Registry in your capital city, or from the AAT website), and
  2. lodged within 28 days of receiving a notification of the ASQA decision that you want reviewed.

Once your application has been lodged, you will receive a letter confirming receipt of the application and telling you what happens next.

What is the AAT’s review process?

In most cases, the first step in a review is a conference. This is an informal meeting conducted by the AAT with you and an ASQA representative. You will have a chance to talk about your case and explain why you think the decision should be changed. The AAT will, where possible, try to help both parties reach an agreement on how the case should be resolved.

The AAT might hold a second conference or another type of meeting, such as a conciliation or mediation meeting. Many cases are finalised at this stage.

If agreement cannot be reached, then the AAT will hold a hearing and make a decision.

The AAT’s procedures and the amount of time needed to complete the review will vary from case to case. The AAT aims to have cases finalised within 12 months.

Timelines for steps in the process are available from the AAT website.

Some useful tips and suggestions:
  1. Read and understand ASQA’s decision on your RTO application and operations: Try to be logical and find out the reasons that have led to the action.
  2. If you are not satisfied with a decision made by ASQA, you can use this link to find a number of options.
  3. Review the publicly available decisions: ASQA links a complete list of all publicly available Tribunal and Court reasons for decisions involving ASQA, in order to assist students and potential students to make an informed decisions about choosing a provider, and provide industry, government and the public with accurate and accessible information on the merits and legality of ASQA’s regulatory decisions.
  4. Apply your case to Administrative Appeals Tribunal: You will get at-least two telephone mediation hearings to resolve your matter with the regulatory body. Apply online
  5. Time to collect information and evidence: Immediately start working on collecting the evidence and information required to support your application. It is important to note that the AATs decision is based on the RTOs level of compliance at the date of the final hearing.
  6. You will need support from experienced VET consultants. Compliance consultants can help you in a number of ways, such as – preparing and collecting your supporting information and evidence, dealing with the regulatory body, and give you the information they have from their past experiences at the Administrative Appeals Tribunal. We at Compliance and Quality Assurance (CAQA) have a number of quality consultants who have represented clients in AAT matters.
  7. You may also need legal advice, so speak to a solicitor who is experienced in VET related matters.
  8. Find relevant information: You can find relevant information from the following websites: 

Industry Expert reveals lessons learnt from 65+ ASQA Audits

Sukh Sandhu’s Interview conducted by EduTemps

During his 20 years in the VET and Higher Education sector, Sukh Sandhu has witnessed a radical shift in compliance landscape. Here he shares his experience on how VET organisations can adapt and thrive in a challenging environment.

Few industry professionals have seen the revolution in VET compliance as closely as Sukh Sandhu. Over a 20-year career in the sector he has worked with a myriad of national and international organisations, including Navitas, MIT, Franklin Scholar, The Malka Group, Australian Catholic University, Melbourne Institute of Technology, Federation University, Gowrie Victoria, TAFE Queensland, Webcom Technologies USA and a number of other educational institutions, universities and RTO’s. He has even worked within Australian Government’s regulatory body ASQA, which served to deepen further his understanding of how RTO’s can successfully navigate the compliance minefield. With 65 regulatory audits and a 100% compliance record under his belt, it’s little wonder that his services are in hot demand. 

The compliance revolution

We began by asking Sukh to outline the key changes he has seen in the compliance environment over his career.

“The changes have certainly been profound. At the core, we have seen ASQA come in as the regulator and together with other government departments, the VET sector is now more closely scrutinised than ever before. At the same time, the sector has become a lot more competitive, with RTOs challenging TAFEs, as well as each other for market share.”

Sukh expanded on major shifts he has witnessed.

“Reforms have been transformative in terms of industry responsiveness, quality and regulations, data and customer information and scrutiny of who is a fit and proper person, to name just a few. Government funding is now more targeted and efficient too and we have seen a much greater degree of collaboration and information sharing between regulatory bodies and government departments.”

“The VET sector has experienced tremendous growth in the number of providers. There are now around 4500+ providers, and around 40% of them have less than 100 students, which is a very different scenario from days gone by. Along with this growth, there has been the collapse of some major organisations, which has been a real wakeup call for the industry.”

The good, the bad and the ugly

In his broad experience, he has certainly seen the best and the worst of the industry.

“It’s true that a few bad apples have tarnished the VET sector in some respects, but there has been a genuine desire to weed out the bad ones, and the regulator has continually updated their approach. There has been a succession of legislative changes introduced since the early 2000’s and along with this the improved collaboration between the regulatory bodies. This has helped clean up a lot of the practices which were dragging down the sector’s reputation.”

Identifying the gaps

So for those RTOs who want to thrive in this regulated environment, what does Sukh see as the main areas to be addressed?

“In my experience, the key areas are assessment and training resources and the strengthening of the capability of trainers and assessors. RTOs must pay particular attention to their trainers’ VET qualifications, their industry currency and their VET currency because this is where major non-compliance issues can emerge. Then there are issues such as short course duration, validation not being done correctly and training assessment strategies and practices not being given proper consideration.”

An active regulatory regime

Sukh observed that ASQA had taken a very proactive approach in enforcing regulations in recent years.

“ASQA has imposed a lot of sanctions on those operators who fail to maintain standards. They are determined to pursue their agenda to maintain the quality of providers in the market and that means RTOs need to be on top of their game.”

He went on to highlight the focus placed on international providers.

“ASQA is looking at the international market in their 2017-2018 regulatory strategy, and this is having an impact. International education is a huge export market worth $28.6 billion a year, and these international students can be very vulnerable.”

Sukh went on to emphasise some other areas in which RTOs must be vigilant.

“There is an overall focus on literacy, language and numeracy and ASQA is reviewing providers who deliver offshore courses. They are looking at how they market their qualifications, how they give students information at each stage of the process and how the agreements are structured. There is also scrutiny on how education agents are approved and how they are reviewed, trained and managed.”

So what advice would he give to an RTO that has a re-registration audit scheduled within the next 12 months?

“RTOs should focus on all the regulatory requirements, SRTOs clauses and standards for domestic and international students, the National code and ESOS for International students, The National standards for ELICOS providers and courses (ELICOS Standards) for organisations delivering ELICOS courses, etc. The main areas of concern will be training, and assessment resources, trainer quality, marketing practices including their website, validation of resources, industry consultation, policies and procedures for governance, administration and operations, training and assessment strategies and the pre-training and enrolment processes are the main areas that need close attention.”

A man on a mission

Sukh’s commitment to the industry stems from a deeply held belief on how vital it is in Australia’s shift toward tertiary and service industries.

“The VET sector is vital for our economy. It plays a really significant role in the job market, by giving students an edge in a competitive market, through the development of skills and clear progression routes. I think we all have a responsibility to ensure that students’ best interests are served, and I feel that the work I do really does help RTOs to provide a quality service that equips students well, at the same times as developing the organisation’s effectiveness and prosperity.”

Read More here…

Tags:vet sectorCompliance