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ASQA VET Sector Consultant and RTO Advisor Briefing webcast, 12 June 2018

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Presenters: Arvid Yaganegi – Manager, Regulatory Operations; Jennine Cochrane – Manager, Regulatory Operations

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ASQA VET Sector Consultant and RTO Advisor Briefing webcast, 12 June 2018

  1. 1. ASQA VET Sector Consultant and RTO Advisor Briefing 2018 Today’s presenters: Arvid Yaganegi – Manager, Regulatory Operations Jennine Cochrane – Manager, Regulatory Operations @asqagovau #ASQAbriefing2018
  2. 2. About today’s session • Regulator update • Changes for new entrants to the training and education market • Q & A #1 • Managing third-party arrangements • Addressing non-compliance after an audit • Q & A #2 Event program
  3. 3. About today’s session • These sessions provide general guidance applicable to a wide audience of providers. • Presenters cannot respond to questions regarding individual applications, audits, complaints or other matters that relate to the particular circumstances of an organisation. Overview
  4. 4. Regulatory update Update on activity and strategies
  5. 5. Compliance at audits 23.9 24.7 18.2 25.8 28.3 76.1 75.3 81.8 74.2 71.7 2013/14 2014/15 2015/16 2016/17 2017/18 (to 31 Mar 2018) At the time of audit Fully compliant At least one non-compliance 77.8 82.4 70.9 53.4 46.2 22.2 17.6 29.1 46.6 53.8 2013/14 2014/15 2015/16 2016/17 2017/18 (to 31 Mar 2018) After rectification
  6. 6. 0 200 400 600 800 1000 1200 1400 1600 1800 2011-12 2012-13 2013-14 2014-15 2015-16 2016-17 2017-18* Audit activity trends * 1 July 2017 – 31 March 2018
  7. 7. Regulatory Strategy 2017-18 • Ongoing close scrutiny of TAE providers and applicants • Strategic review of international education providers • Increasing scrutiny on new VET and CRICOS market applicants Key areas 6
  8. 8. Regulatory Strategy 2017-18 • Reviewing available data and identifying risk indicators for international VET and English language education services delivered by ASQA-regulated providers • ‘Providers of interest’ subject to targeted assessment of practices and behaviours International education strategic review 7
  9. 9. Regulatory Strategy 2017-18 • Reviewing both onshore and offshore delivery arrangements and regulatory practices • Looking at provider best practice • Enhancing communication with providers to improve practices • Reporting in the 2018-19 financial year. International education strategic review 8
  10. 10. New entrants to the VET market Raising the bar for new providers from 1 July 2018
  11. 11. Video here 10
  12. 12. Why is ASQA ‘raising the bar’? • High numbers of applicants: ‒ lacking educational capability ‒ with insufficient financial resources or facilities ‒ ‘non genuine’ (no intent to provide quality training) ‒ rely excessively on consultants for initial registration and do not develop the organisation’s long-term capacity • Rejected applications require significant ASQA resources • New providers often grow scope rapidly soon after registration Impact to sector and quality providers from: 11
  13. 13. Why is ASQA ‘raising the bar’? • Ensure registration as a provider is only granted to organisations that are adequately resourced and have a genuine interest in providing high quality training and assessment • Ensure appropriate controls are placed on new providers subsequent to market entry • Improve the quality of new providers to the market ASQA’s aim is to: 12
  14. 14. 13 New self assessment & supporting evidence Strengthened Fit and Proper Person declaration Strengthened Financial Viability Assessment No change allowed to application once submitted What is changing? Revised application process
  15. 15. Revised application process • Self assessment tool covers the ‘standard’ Clauses or Standards for VET, CRICOS and ELICOS • Helps providers ensure they are resourced and prepared to operate before lodging application • Supporting evidence of compliance is submitted at time of application • Application guide and asqanet form revised to align to changes 14 New self assessment & supporting evidence
  16. 16. Revised application process • Includes all underlying assumptions, such as: • Student number and course costs projections • Staff numbers and salary projections • Business plan must be submitted with tool • Makes it clearer to applicants if they are financially resourced New Financial Viability Risk Assessment Tool 15 Strengthened Financial Viability Assessment
  17. 17. Revised application process • More disclosure about relevant matters required • More disclosure about associations required • More people may be required to complete, for example: • All managers • Consultants • Agents • Ultimate owners Strengthened FPP declaration 16 Strengthened Fit and Proper Person declaration
  18. 18. 17 Additional scrutiny to ensure requirements met No rectification provided Audit made up of desk and validation component What is changing? Revised assessment process
  19. 19. Revised assessment process • Additional checks conducted in IAR and Regulatory Operations for Fit and Proper person issues and associations • Financial Viability decision now made by Regulatory Operations as part of audit 18 Additional scrutiny to ensure requirements met
  20. 20. Revised assessment process • Fit and Proper Person (Clause 7.1), Financial Viability (Clause 7.2) and AVETMISS data (Clause 7.5) included in scope of audit • VET standards always audited as part of CRICOS application for VET training products 19 Additional scrutiny to ensure requirements met
  21. 21. Revised assessment process • Audit made up of desk component and validation component • Self assessment, Financial Viability tool and supporting evidence and reviewed in desk component • Validation component validates evidence provided in desk component and resourcing 20 Audit made up of desk and validation component
  22. 22. Revised assessment process 21 No rectification provided Audit Rectification Decision Reconsideration AAT
  23. 23. 22 2 year registration period Additional scrutiny on VET change to scope applications Must demonstrate quality training and assessment to be renewed after 2 years What is changing? After registration
  24. 24. Post registration changes New providers only granted 2 year registration: • Apply to renew during 2 years • Undergo a renewal audit in lieu of a post initial audit • Application rejected if no delivery has occurred 23 2 year registration period Some providers exempted from this requirement, e.g. WA and TAC transfers or TAFE mergers
  25. 25. Post registration changes Providers applying to change scope prior to the ‘renewal’ audit: • Required to resubmit Financial Viability documents i.e. business plan, underlying assumptions, bank statements • Will undergo a small scope desk audit to ensure adequately resourced - Clauses 1.1, 1.2, 1.3, 7.2 24 Additional scrutiny on VET change to scope applications All transition applications excluded from this requirement
  26. 26. 1 July 2018 implementation • Additional scrutiny on change applications applies to all providers in their first two years of registration • New requirements apply if you seek additional registration (eg RTO registration for additional company involving the same individuals or adding CRICOS registration) What will the changes mean for you?
  27. 27. More information • Detailed guidance on ASQA’s website • New resources including application guide, self-assessments for VET and CRICOS, Fit and Proper Person declaration, Financial Viability Risk Assessment tool • Applications submitted on or before 30 June 2018 can choose whether to use new tools • Applications submitted on or after 1 July 2018 must use new tools Resources available now 26
  28. 28. Addressing non- compliance after an audit Case studies
  29. 29. Addressing non-compliance If non-compliances are identified, ASQA may require a provider to do one or both of: • address the non-compliance so that future learners will not be negatively affected • identify the impact the non-compliance has had on past learners and carry out remedial action to address this impact Future learners and current/past learners may be affected 28
  30. 30. Introduction • Less than 30% of providers fully compliant at time of audit • Even quality providers may find action to address non-compliance is needed • Most challenging standards to address non-compliance with: – 1.2 Amount of training – 1.8 Assessment – 2.1 Third-party arrangements Common areas of non-compliance 29
  31. 31. Clauses 1.2, 1.8 and 2.1 Levels of compliance in 2017 30 Clause Relevant area Compliance at audit Compliance after rectification 1.2 Amount of training 53.0% 68.5% 1.8 Assessment 28.5% 46.7% 2.1 Third-party arrangements 23.7% 40.3%
  32. 32. Case study ‘Hospitality 123’ delivers certificates I – IV in hospitality to several learner cohorts: new entrants to the industry, those who have been in the industry for some time, individuals in a defined age bracket, and job seekers. Clause 1.2: Amount of training
  33. 33. Hospitality 123 The provider is found to be not compliant with clause 1.2 “For the purposes of Clause 1.1, the RTO determines the amount of training they provide to each learner with regard to: a) the existing skills, knowledge and the experience of the learner b) the mode of delivery and c) where a full qualification is not being delivered, the number of units and/or modules being delivered as a proportion of the full qualification.” Issues found at audit 32
  34. 34. Hospitality 123 • ASQA finds issues with the training and assessment strategy which include: ‒ Learner cohorts not defined ‒ One-size-fits-all strategy ‒ Amount of training not defined ‒ Training not separated from assessment ‒ Very short duration with minimal training ‒ Large amounts of ‘self-paced learning’ with no rationale ‒ No rationale on how the amount of training was determined Issues found at audit 33
  35. 35. Hospitality 123 • Hospitality 123 must address non-compliance with Standard 1.2 • ASQA asks Hospitality 123 to undertake remedial action for current and past learners as: ‒ Students may have completed the training program without adequate skills due to the short duration of delivery ‒ Students may not have met the requirements of the training product Issues found at audit 34
  36. 36. Hospitality 123 • Identify the learner cohorts • Develop appropriate training and assessment strategies for each cohort • Ensure strategies meet the training package requirements • Define amount of training • Outline rationale for amount of training • Specify mode of delivery • Undertake industry engagement on assessment practices Action taken to rectify non-compliance for future students must 35
  37. 37. Hospitality 123 Remedial action could include: • Additional training and further assessment for current learners • Offering past learners the opportunity for gap training and further assessment Possible remedial action 36
  38. 38. Hospitality 123 • New/modified training strategies incorporating rectifying the deficiencies identified by ASQA • Outline of schedule for training current students • Gap analysis conducted to determine remediation requirements for past students • Evidence of remediation undertaken • Confirmation from students’ employers outlining competence Evidence of compliance provided to ASQA 37
  39. 39. Case study Northside Health Training delivers health and community care qualifications. An amendment to scope audit was conducted on the RTO in December 2017. The RTO had applied to add Diploma of Nursing to its VET scope. Clause 1.8: Assessment
  40. 40. Northside Health • This audit sampled current practice in relation to delivery of CHC33015 Certificate III in Individual Support and CHC43015 Certificate lV in Ageing Support • ASQA found non-compliance with assessment of CHCCCS011 Meet personal support needs and HLTAID003 Provide first aid. • The provider is found to be not compliant with clause 1.8. Issues found at audit 39
  41. 41. Northside Health • Requirements of the relevant training package not being met • Principles of Assessment and Rules of Evidence not being met • Lack of practical application of skills and knowledge • Lack of assessment criteria • Inconsistent assessment of learners • Lack of clear instructions regarding the task to be performed • Many instances of inadequate evidence of competency Issues with assessment practices: 40
  42. 42. Northside Health • The RTO must provide evidence that shows that it has: - corrected its assessment system to comply with Clause 1.8 for future students - systems in place to ensure this system is applied - carried out remedial action to identify and address the impact the non-compliance may have caused to students in the units sampled. Action required to address non-compliance 41
  43. 43. Northside Health Remedial action needs to cover current students and students who were assessed by the RTO in the past six months from the date the audit was conducted. The units are: • HLTAID003 Provide first aid • CHCCCS011 Meet personal support needs. Action required to address non-compliance 42
  44. 44. Northside Health • Northside Health must address non-compliance with Standard 1.8 • ASQA asks Northside Health to undertake remedial action for current and past learners as: ‒ Students have not been trained or assessed to meet the requirements of the relevant training package ‒ Sampled student files are incomplete and assessment records are inconsistent Issues found at audit 43
  45. 45. Northside Health Training • The organisation has corrected its assessment system, to comply with Clause 1.8 • The organisation has also taken remedial action to address the affects of the non-compliance on past students Action taken to address non-compliance 44
  46. 46. Northside Health Training • Statement outlining the number of affected students • Evidence of re-assessment workshop held with affected students (dates, attendance forms with signatures, observation checklists) • Sample photos of simulated environment • Photos of students whose files were sampled at reassessment Evidence provided to ASQA 45
  47. 47. Case study Big Business RTO has several third-party arrangements one with a school, North Spring Secondary College, which has around 50 students, one with a finance company, New Melbourne Finance, which is funded by the Victorian Department of Education, and two with employment agencies. ASQA identifies concerns with the agreements and how they are implemented and monitored. Clause 2.1: Third-party arrangements
  48. 48. Big Business RTO Third-party agreement with ‘North Spring Secondary College’: • Lack of oversight • All files and records are kept at the school • AVETMISS not up to date • Little scrutiny of compliance Issues found at audit 47
  49. 49. Big Business RTO Third-party agreement with ‘New Melbourne Finance’: • The contractual arrangements do not make clear who is responsible for compliance • The contractual arrangements do not set out which training and assessment strategy is relevant Issues found at audit 48
  50. 50. Big Business RTO Third-party arrangement with employment agencies: • Short duration training • Low completion rates • Unclear when and if students attend class Issues found at audit 49
  51. 51. Big Business RTO The RTO needs to: • demonstrate how compliance is monitored for each third party • ensure that they have effective training and assessment strategies for student cohorts at third-party providers • have signed, written agreements that explain each party’s responsibilities Action taken to address non-compliance 50
  52. 52. Big Business RTO • Copies of written and signed agreements with each third party that: ‒ clearly outline the responsibilities of each party ‒ describe how Big Business will oversee the agreement • Evidence showing student management system is being updated Evidence demonstrating compliance 51
  53. 53. Big Business RTO Training and assessment strategies for third-party student cohorts showing: • amount of training • student pathways • support provided • assessment processes • training resources • trainer vocational competency Evidence demonstrating compliance 52
  54. 54. Big Business RTO Show better management of agreement with employment agencies, for example: • Revised training and assessment strategy with amount of training • Delivery and assessment schedule/timetables/attendance records • Evidence showing student support services available Evidence demonstrating compliance 53
  55. 55. Questions? 54
  56. 56. More information ASQA Info Line – 1300 701 801 Email – enquiries@asqa.gov.au Website – asqa.gov.au @asqagovau

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