“Recover successfully from non-compliant audit reports”

WA Training Providers Forum

20 May 2014

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Our Vision

To be the first choice amongst Consultants across Australia in the

area of education and training. Our clients will be recognised as

leaders and providers of excellence in their respective fields.

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Who are we?

Founding Director- Raelene Bartlett

• Established RTO Doctor 3 ½ years ago

• Qualified secondary & adult teacher with various postgraduate

degrees

• Over 17 years in the education & training industry in variety of roles

• Raelene has had the privilege of working with a range of experts in: – Schools

– VET

– ELICOS

– Higher Education

– International

• Experience in many roles as a private provider and a regulator

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Who are we?

The Doctors

• Skills, experience & advice from CEO’s to trainers to the students

themselves to offer you and your business a truly amazing service,

unique to the industry.

• It is this intricate integration of experience from every participant in

the learning journey that separates us from our competitors.

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Instructions

• Interactive Session using Poll

Everywhere

• Instructions for participation (Virtual

Satchel) and at the door

• Audience Voting – How

– Important information

– Practice poll

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Participating with Poll Everywhere How to vote via the web or text messaging

Pollev.com/rtodoctortpf14

0427 541 357

(code or keyword) <your response>

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Participating with Poll Everywhere How to vote via the web

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Participating with Poll Everywhere How to vote via SMS

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Practice Poll

• What is your position in the VET sector?

– Trainer and assessor

– RTO Senior Management

– CEO

– Administrative Staff

– Other

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Overview

• Importance of the right help – Consequences of getting it wrong

• A few definitions

• Discussion ASQA Statistics

• How do I know if my evidence stacks up?

• Presentation of evidence is key

• Sample Standards

• Options Post-Audit

• Questions

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The Right Help

• Understanding the issues

• Use your time wisely

• Engaging Assistance

– Due Diligence is critical!

– Ask around

– AVQPCA & The Diamond Standard

• Develop an action plan

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Getting it Wrong

• Worst case scenarios – Suspension

– Cancellation

• Increase of risk rating – Increased regulatory focus

– Current focus on deregulation for best practice providers – 20%

• Financial

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Definitions Non-Compliance • Critical

– The requirements of the AQTF / VET Quality Framework have not been met, based on the evidence reviewed, and there is a critical adverse impact on learners and/or consumers of goods and services produced in the training environment or the current (or future) workplace.

• Significant – The requirements of the AQTF / VET Quality Framework have not been met, based on the

evidence reviewed, and there are indications of a significant adverse impact on learners and/or other consumers of goods and services produced in the training environment or the current (or future) workplace.

• Minor – The requirements of the AQTF / VET Quality Framework have not been met, based on the

evidence reviewed, but there is no, or minor, adverse impact on learners and/or other consumers of goods and services produced in the training environment or the current (or future) workplace.

• Rectification – The process of remedying the identified non-compliances to the regulator’s requirements

• Due Diligence – Undertaking a confirmation of someone’s qualifications, knowledge, skills, professional

indemnity insurance, business terms, consumer protection mechanisms

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Question

• Thinking about compliance within your

organisation, what level do you think

your non-compliance might be?

– Critical

– Significant

– Minor

– None

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ASQA Statistics 1 July 2011 – 30 June 2013

• 91 renewals of registration were refused (ASQA chose to cancel/suspend or refuse the re-registration of 165 individual existing RTO’s).

• 277 amendments to scope were refused.

• 90 initial RTO applications were refused.

• ASQA presentations through 2013 advised in the 12 months to June 2013:

• 76.5% of RTO’s audited had at least one (1) non-compliance identified.

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Does my evidence stack up?

• Identify what evidence the auditor was looking for

• Using evidence provided at audit

– Compare your evidence to the requirement of the standard

– Be honest (it’s only you and your team asking the question)

– Is it sufficient?

– Is it current?

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Presentation of Evidence • Develop a table of the non-compliances

Identified Non-Compliance

Proposed Evidence

Responsible Date for Completion

The RTO did not provide evidence to demonstrate that trainers/assessors delivering BSB50207 Diploma of Business meet the requirements of SNR15.4 (AQTF 1.4)

Trainer / assessor competency & currency matrix for each unit being delivered & assessed: • Rachel Brown • Trevor Giles • Alex Scott

John Black 31 May 2014

While CV’s and staff skill matrices of individual trainers/assessors were sighted in individual trainer/assessor files, documents supporting these claims were not sighted at audit including for example verified testamurs of qualifications

Each trainer/assessor file has verified copies of testamurs, records of results, reference checks, etc. on file for: • Rachel Brown • Trevor Giles • Alex Scott

John Black 31 May 2014

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Presentation of Evidence • Develop a table of the evidence & location

Identified Non-Compliance

Actual Evidence Location

The RTO did not provide evidence to demonstrate that trainers/assessors delivering BSB50207 Diploma of Business meet the requirements of SNR15.4 (AQTF 1.4)

Trainer and Assessor Profile for: • Rachel Brown • Trevor Giles • Alex Scott Covering each unit being delivered & assessed by each trainer/assessor.

SNR15.4 under

each trainer/assessor

name

While CV’s and staff skill matrices of individual trainers/assessors were sighted in individual trainer/assessor files, documents supporting these claims were not sighted at audit including for example verified testamurs of qualifications

Electronic version of verified copies of testamurs, records of results, reference checks, etc. on file for: • Rachel Brown • Trevor Giles • Alex Scott

SNR15.4 under each

trainer/assessor name

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Sample Standard SNR 15.2 (AQTF 1.2)

– Strategies for training and assessment meet the requirements of the relevant training

package or accredited course and are developed in consultation with industry

• Break it down – Training and assessment strategies

– Meet training package / accredited course requirements

– Developed in consultation with industry

• Poll Question

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Poll Question

What evidence might you present for:

“Training and assessment strategies meet the requirements of the

training package / accredited course”?

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Common Examples of Evidence

• The Training and Assessment Strategy (TAS) includes for example:

– Qualification packaging rules

– Entry requirements

– Co-requisites & pre-requisites

– Required Trainer and Assessor competencies

– Industry consultation evidence for the development of the qualification

– Mode of delivery and assessment

– Resource requirements

– Target group - address any special needs

– Licensing requirements

– External accreditation or endorsement requirements

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Sample Standard

SNR 16.1 (AQTF 2.1)

– The RTO establishes the needs of its clients and delivers services to meet those needs

• Break it down – Identify student needs

– Deliver services to meet identified needs

• Poll Question

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Poll Question

What evidence might you present for:

“The RTO establishes the needs of its clients and delivers services to meet

those needs”?

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Common Examples of Evidence

• Evidence that can be used includes:

– LLN assessments undertaken pre-enrolment

– Completion of AVETMISS data on the enrolment form

– Employer / Trainee interview notes

– Industry consultation regarding target group needs

• For example, prison education officers may indicate high levels of need for significant LLN support, security issues regarding resources and equipment

– Provision of or referral to LLN support services

– Provision of learning in alternative formats

– Study Support timetables and attendance records

– Implementation of support programs such as CAVSS

– Increased monitoring of course progress

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Sample Standard

SNR 17.4 (AQTF 3.4)

– The RTO manages records to ensure their accuracy and integrity

Break it down – What student records do we have?

• Hard copy admin files

• Hard copy academic files

• Student Management System

• Moodle / Learning Management System

– How do we manage their accuracy?

Poll Question

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Sample Standard

What evidence might you present for:

“How does the RTO manage its records to ensure their accuracy and

integrity”?

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Common Examples of Evidence

• Evidence that can be used includes:

– Information collected and monitored in accordance with policies and

procedures

– Completed AVETMISS records

– Student Management System records match hard copy records

– Internal audit results confirming accuracy and integrity check

– Records are backed up routinely and effectively protected

– RTO meets the requirements for retention of records

– Staff induction covering responsibilities for record keeping

– Records are systematically managed (Student Management System

Manuals, Learning Management Manuals, etc.)

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Poll

“Briefly, in a few words, what do you believe are your record

retention requirements?”

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Record Retention Enrolment records (ALL Regulators) • All records of enrolment will be kept for a minimum

of 30 (thirty) years from the date the student finished his/her training.

Assessment records (ASQA) • An RTO is required to securely retain, and be able

to produce in full at audit if requested to do so, all completed student assessment items for each student, as per the definition above, for a period of six months from the date on which the judgement of competence for the student was made.

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Record Retention Assessment records (All Regulators) • Government-funded agreement or contract, RTOs

must consider the record-keeping requirements of

that agreement or contract.

• Regulated/licensed outcomes may also impose

specific records retention requirements.

• Complaints and appeals processes

• CRICOS providers have additional requirements

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Record Retention Assessment records (TAC) • Government-funded agreement or contract, RTOs

must consider the record-keeping requirements of

that agreement or contract.

• RTO’s are required to retain certain documents for

the purposes of auditing for a period of at least five

(5) years including:

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Record Retention Assessment records (TAC)

– Attendance records incl. names of students, unit identifiers, attendance date, trainer signature

– Record of assessment and/or training record book

– Training and assessment policies and strategies for all courses

– Assessment tools and instruments

– RPL assessment records

– All AQTF policies and procedures

– All financial, enrolment and assessment records relating to performance agreement with the Department

– Complaints and appeals

• No requirement to retain originals or copies of student work for auditing, recommendation however that some are retained for moderation purposes.

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Record Retention Assessment records (VRQA) Details of: • Policies and procedures and processes for the retention unit o

f competency training and assessment information *for a minimum period of 1years

• post completion of the unit, including:

– mechanisms for the retention of master copies of student assessments and training resources

– mechanisms for the retention of sufficient samples of students’ assessment to demonstrate that quality education and training has occurred

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Record Retention Assessment records (VRQA) Information must include:

• The assessment schedule for that unit

• A copy of all assessment tasks, including tests, assignment, role plays, projects etc. for the unit

• A copy of any workplace / flying log or workbook used by students to provide evidence of competency including a copy of at least one a sample completed workbook

• Copies of samples of student assessments, including workplace /flying logs or workbooks, together with results. A Competent C and Not Yet Competent NYC

• Assessment for each discrete assessment task. (At a minimum the sample would comprise one piece of work assessed as C for each required assessment task)

• A copy of the overall results by student, for that unit.

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Options Post Audit Immediately Rectification

• Start rectifying as much as possible based on the exit interview and your notes while you wait for the final audit report

Acceptance of Findings

• Complete rectification as per the audit report

• Present suitable evidence

NOTE: Everything you submit is considered evidence (if all you submit by the due date to the auditor is a letter complaining about the process and your disagreement with the findings, this will be considered your evidence)

Appeal the Findings

• Follow the process for appeal with your regulator

Administrative Appeals Tribunal

• Worst case scenario

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Poll

“What has been the most valuable piece of information presented for

you in this session?”

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Questions

Do you have any questions?

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