Some of Australia’s vocational training institutions, especially private colleges and Registered Training Organisations (RTOs) have emailed their students currently stranded overseas to deposit their fees or else their Certificate of Enrollment (CoE) may be cancelled
A good Quality Management System provides a centralised mechanism for managing an organisations policies and procedures. These quality documents are a collection of processes that outline how you do business and meet your customers’ expectations. A core function of a QMS is to manage its document control functions.
Quality Management System Framework:
The most commonly known framework used is ISO 9001 but unless your RTO is ISO accredited there is no need to create a QMS that reflects the requirements of these standards. At a minimum your QMS should meet what is required of the VET Quality Framework and any other legislative requirements or regulatory obligations you must adhere to. The main components of your system should incorporate your quality manual or policies and procedures; your organisational structure; your document control processes and your internal audit / continuous improvement processes.
In addition to policies and procedures your quality documents can consist of but are not limited to work instructions; guidelines; templates; plans and forms. Quality documents such as policies and procedures are usually approved by document owners who are typically in RTO management positions. Other staff can contribute to the development of the documents and provide feedback on the content as it is important to ensure buy in by staff who are going to have to adhere to processes or use the tools.
Document Control Procedure:
Your RTO should have a procedure that sets out the processes for managing your quality documents or your policy and procedure library. This includes how you categorize the documents; the naming conventions used and numbering systems assigned to documents. It should also provide instruction on version control and also detail how often the documents are reviewed and updated to ensure they are fit for purpose. Controlled documents are needed for regulatory compliance purposes and are critical in ensuring your RTOs meets all legislative requirements or regulatory obligations.
Setting up your QMS:
EDministrate can help your organisation design, create and implement a QMS and create an efficient and effective documentation system or help you update your existing QMS to ensure it is fit for purpose therefore ensuring your RTO delivers quality products /services to your customers. Our Compliance Plan and Compliance Plan Matrix Template provides a reference to critical quality documents in your business that you can use to map how your policies and procedures ensure you meet all RTO compliance obligations.
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Training and assessment strategies do not reflect information contained in marketing material:
The information contained in your TAS’s needs to be consistent with the information you are marketing on your website and other marketing material. Details around course durations; course descriptions; attendance / participation requirements; entry requirements or selection criteria should be accurate in both sources. ASQA often finds non-compliances at audit and with applications for additions to scope in evidence submitted as RTOs can fail to pay attention to details with this critical data. Remember your websites are publicly available and can be accessed by ASQA at any time.
Failure to ensure trainers are maintaining their profiles:
Some RTOs make assumptions that their trainers are current because they are working in industry or appear to be undertaking professional development regularly however, they fall down because they don’t sufficiently document these activities systematically and on a consistent basis. In an audit ASQA wants to see a documented analysis e.g. mapping of how your trainers / assessors meet industry currency requirements for each unit of competency they are delivering. If you don’t have a process in place to document these requirements at the unit of competency level you will not satisfy the requirements of the relevant clauses in the SRTOs 2015. Remember mapping should be at least at the element level for each unit to demonstrate that the maintenance of currency has addressed all the requirements.
Assessment tools do not meet the requirements of the unit of competency:
Not having a process in place to validate / quality check assessment tools pre-use puts your RTO at potential risk of non-compliances as you have not determined if your assessment tools are fit for purpose and meet the requirements of the specific unit of competency. If you implement these resources without conducting this due diligence you could be impacting on student and industry outcomes and be deemed critically non-compliant in an audit.
Assessment tasks have insufficient instructions for students and assessors:
Assessors cannot collect sufficient evidence from students if assessment task instructions are vague and unclear. This in turn can impact on marking; recordkeeping and overall reliability of the assessors judgement. Instructions in assessment tasks need to be specific as possible. Benchmark answers and marking guides should be explicit and not be open to interpretation by assessors.
No benchmark answers or marking guides for assessment tasks:
If you do not have benchmark answers or marking guides for your assessors to refer to when making their judgements you cannot ensure your assessor is meeting the rules of evidence. Your assessors practices will not be consistent without these critical documents to refer to.
Read more here: https://www.asqa.gov.au/news-
The compliance of your training and assessment strategies will be tested by ASQA either when you submit them with an application to add a training product to scope or during a regulatory audit. Therefore, it is critical your RTO has effective processes in place to ensure that these mandatory compliance documents are developed to meet the requirements of the relevant clauses in the SRTOs 2015.
Your training and assessment strategies are the source documents for your RTO’s academic planning related to the training and assessment for all training products on scope. It is important that your TAS template is fit for purpose and designed to capture all of the critical information required. At a minimum your RTO should use a TAS template that captures information for the following aspects:
- The training product is identified including the code and full title as per the National Register;
- Core and elective components for delivery of full qualifications are identified as per the packaging rules and for partial delivery of qualifications or stand-alone units the specific units of competency being offered are listed;
- Entry requirements are explained including mandatory requirements of the training product and any additional requirements as per your RTO policies;
- Pre-requisite and co-requisite units are identified;
- Sequencing of the delivery and assessment is explained;
- The student cohort/s and their characteristics are identified including any existing knowledge, skills and work experience.
- Mode of delivery is identified e.g. face-to-face, online, workplace training or mixed mode
- Duration and scheduling of your program is provided detailing your amount of training hours that are appropriate for the student cohort/s
- Assessment resources, methods and timing are identified including mandatory work placement arrangements
- Learning resources are identified
- Appropriately qualified trainers and assessors are identified for each unit of competency being offered
- Essential physical resources are identified for each unit of competency being offered including facilities such as workshops and labs, equipment and training aids
ASQA suggests that a TAS may comprise of multiple documents but there must be consistency between these documents so that the overall strategy is clearly described. You may decide to have separate documents as addendums to your main document for lists such as your staffing matrix, physical resource list or learning and assessment resource list and this is ok. If you do this you need to ensure that the addendums and their locations are clearly referenced in your main document.
EDministrate has developed a fit for purpose Training and Assessment Strategy Template that has been designed to meet all the compliance requirements should your RTO need to replace what you are currently using.
Using a well-designed, practical checklist as a reference when developing your TAS’s ensures the most critical and important steps are not missed in the process. Checklists ensure self-accountability for the staff responsible for creating the documents and overall consistency in the process across your organisation. We have a good TAS validation checklist available for free download should your staff want to implement this in your RTO.
There are numerous places from which you will need to draw the information required for your TAS such as the National Register; training package implementation guides; accredited course syllabuses and other RTO planning documents. The information you input will impact on the compliance of your document and will only be as good as the reliability of the source. Your RTO should have clearly defined processes preferably documented in a procedure that explains how you will ensure the quality of the content in your TAS.
RTOs must comply with Clause 2.2 in the SRTOs 2015 which requires systematic monitoring of its training and assessment strategies and practices. This includes having processes in place to evaluate RTO products and services and using feedback to improve its strategies and practices. Therefore, RTO’s must have effective systems in place to ensure quality checks of compliance documents are embedded in its quality assurance. This should include reviews of TAS’s at regular intervals that determines their effectiveness and implementation in the organisation. Having a documented schedule of quality checks undertaken on TAS’s provides valuable evidence and ensures your RTO is sufficiently prepared in the event of an ASQA audit.
Management is accountable for ensuring the quality of training and assessment of a RTO’s course offerings. Therefore, it is important that your RTO has an approval process in place before each TAS is implemented in your organisation. Having this management oversight will ensure the documents are consistent with your RTO’s actual training and assessment strategies and practices.
Planning is critical to your businesses success. Your RTO needs a road map that clearly defines its business goals, future direction and, most importantly, sets out a clear pathway of the tactics and strategies that will get you there.
“Plans are worthless but planning is everything” Dwight Eisenhower
There are three major types of planning generally used in business which includes strategic, operational, and tactical planning. A fourth type of planning, known as contingency planning, is an alternative course of action, often developed to explore and prepare for any eventuality. Contingency planning should be developed in conjunction with an organisation’s business continuity plan.
Your RTOs planning framework should provide a system for aligning priorities, making decisions, allocating resources, and measuring its impact. Outcomes of this approach should result in absolute clarity about your RTO’s mission, purpose, and direction; significant revenue and customer increases; value-based performance reviews; and increased engagement and satisfaction among staff.
Planning systems principles
A framework suited to businesses such as training organisations or educational institutions is one aligned to Hoshin Kanri planning principles. Hoshin planning consists of a seven-step cycle, beginning with high-level strategic objectives and ending with local-level improvement targets:
- Establish organizational vision
- Develop 3-5-year strategic plan
- Develop annual objectives
- Deploy to departments to develop plans including targets and means
- Regular progress reviews monthly and quarterly
- Annual review
The principles of the PDCA continuous improvement cycle are heavily embedded into the Hoshin planning process.
There are different types of plans and planning tools commonly used in business that differentiate between an organisations long term, short term and operational objectives:
A strategic plan provides the framework to communicate your RTOs organisational goals, the actions needed to achieve those goals and includes a vision statement; a mission statement; and details on when the plan will be reviewed and updated. It is the CEO’s responsibility to make sure that changing conditions (both external and internal) are reflected in the RTOs long-term or strategic plan. The larger and more complex the RTO, the larger and more complex the strategic plan will be to include all of the individual departments and functions.
An operational plan sets out the tasks that your RTO needs to perform in order to reach a certain outcome. It is a blueprint of sorts, aligned with the objectives outlined in your RTOs strategic plan. Different managerial levels have responsibility for implementing different types of short-term or operational plans. Essential short-term plans for RTOs include validation plans, industry engagement plans or resource development plans as they define specific objectives critical to your business operations.
A team plan identifies the contribution the team will achieve to your RTOs operational plan. By aligning the team plan to the operational plan, you can ensure their performance can be directed to ensuring they achieve the goals in the operational plan.
An Individual plan links your RTOs objectives to those of the individual.
Project Management Planning:
Many RTOs neglect implementing formal project management processes within their business. Project based management is a generic skill required of all managers. Projects are a temporary organisation where resources are assembled to do work and to deliver a result or asset. Documenting your goals, identified risks, roles, timeframes and deliverables in project plans allows project managers clear oversight of resources allocated. Failure to deliver the desired product or service occurs when businesses have inadequate systems in place for planning and executing of projects.
The relevant VET accredited courses will remain on RTOs scope of registration until the end of the extended teach-out period unless the RTO chooses to withdraw it from scope prior.
Receiving a notice from ASQA:
Under the National Vocational Education and Training Regulator Act 2011 (NVR Act), ASQA may issue notices such as a notice of intention to make a decision to an RTO as a result of an audit conducted or complaint received about your RTO by the national regulator. The NVR and ESOS Acts provides ASQA with the powers to apply sanctions of increasing severity—starting from written directions and additional conditions on registration through to suspending or cancelling a provider’s registration. In the event your RTO receives this type of correspondence from ASQA it is critical you understand how to respond to the proposed sanctions effectively to ensure you do not lose your RTO’s licence to operate.
The RTO senior leadership must immediately take action to address the issues identified in the notice and commence working on a plan to respond to ASQA. EDministrate recommends seeking legal advice if the proposed sanction refers to cancellation, rejection of application to renew registration or suspension so you are well informed and clear on your legal options. It is important that the RTO senior leadership remains calm and level headed during this time. Roles and responsibilities of staff involved in contributing to your RTO’s response to ASQA must be clearly defined and expectations communicated to ensure the actions taken are appropriate. If you are the CEO of a small RTO with little or no other senior staff you may consider seeking the support of external consultants such as EDministrate to help you plan your response and next steps.
One of the first steps that should be taken in this matter is to identify internal capability within your RTO. Do you have the expertise in house to prepare your response to ASQA and take the required actions i.e. rectifications and remedial action? If not seek assistance from compliance experts such as EDministrate. While your RTO must continue to operate business as usual while you respond to ASQA’s notice you need to ensure that this issue is given absolute priority in your business so you meet the required deadline and you satisfactorily address all issues identified by ASQA .
If there are extenuating circumstances preventing you from providing your response to ASQA by the deadline given you must contact them immediately to request additional time so that they can consider your case. Failure to do this could have an adverse impact on you successfully addressing the issues identified and meeting the required timeframe. It is also critical that you develop a communication strategy to address any concerns your students or other clients may have should they become aware of proposed action against your RTO. It is extremely important that you manage any potential reputational damage that could be caused by regulatory action taken against your RTO to limit any negative impact on your business.
Submission of annual declaration:
RTOs must submit their annual declaration on compliance by midnight 31 March. ASQA has sent an email on Friday 21 February 2020 to each RTO’s Chief Executive Officer (CEO)containing a unique URL to the RTOs survey. A reminder email was also sent by ASQA to CEO’s on Friday 13 March 2020 advising of the requirement.
If the CEO’s email has not been received by your RTO check your details in ASQAnet urgently and take action to rectify any errors with contact details. Notify ASQA immediately so the email with the survey link can be sent to the CEO. Not receiving the email is not an excuse to fail to submit your RTO’s declaration as it is a requirement of the Standards for Registered Training Organisations (SRTOs) 2015.
RTOs are required to adhere to Clauses 2.1; 8.1; and 8.4 specifically in the SRTOs 2015:
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 an RTO within its scope of registration.
The RTO cooperates with the VET Regulator:
- by providing accurate and truthful responses to information requests from the VET Regulator relevant to the RTO’s registration
- in the conduct of audits and the monitoring of its operations
- by providing quality/performance indicator data
- by providing information about substantial changes to its operations or any event that would significantly affect the RTO’s ability to comply with these standards within 90 calendar days of the change occurring
- by providing information about significant changes to its ownership within 90 calendar days of the change occurring
- in the retention, archiving, retrieval and transfer of records.
The RTO provides an annual declaration on compliance with these Standards to the VET [vocational education and training] regulator and in particular whether it:
- 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
- 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.
Whether the CEO completes the declaration on their own or in consultation with RTO compliance staff the responses provided should be honest and accurate. Therefore, reliable sources of data must be referred to when responding to each question asked in the survey. Information from the RTOs internal audits, reviews or quality checks are critical indicators of the RTOs past and current compliance status. If your organisation has adhered to Clause 2.1. by ensuring it is compliant with the SRTOs 2015 at all times you should have been ‘systematically’ monitoring the RTO’s compliance and have analysed the data obtained by your compliance activities.
If your RTO does not have current and reliable data on its compliance status you should follow ASQA’s advice provided in the correspondence sent to the CEO and utilise ASQA’s Self-Assessment Tool to assist in preparation of the annual declaration. If your RTO does not have the capability or resources to undertake the self-assessment or preparation of the annual declaration then seek assistance from experts like EDministrate to ensure you fully comply with ASQA’s requirements.