Learning new tricks in education; what RTOs need to learn from the TAFESA and other provider Audit Reports

It's been just over a year since the new ASQA Audit Model was introduced. The new model focuses on application of the standards, as opposed to simply having the correct policies, procedures and tools; staff actually have to apply the procedures.

At the same time, it's been a year since UTAE launched our Trainer Development System and boy, was it good timing! Our system focused on helping trainers learn how to apply the Principles of Assessment, Rules of Evidence, etc in a highly targeted and effective format using principles of micro learning and taking into account the challenges of trainers and VET Practitioners.

However, many RTOs still struggle to get staff to understand a crucial link; how the RTO Standards are built into the policies, procedures and tools and how those then need to be applied in order to ensure a quality outcome. And the result is that when auditors speak with students and staff during audits, the student experience and evidence of competency is not line with either; the Standards or company policy and procedure. The result? The Training and Assessment process is diminished...

I read audit reports continually, many would have read TAFESAs audit report (or some of it) in the latest fiasco tainting the name of VET and dragging everyone back into the public v private debate, which I won't get into other than to say there are good and struggling providers on both sides. I have provided quotes from both private provider reports and the TAFESA reports for good measure. Please note that all the information I have referenced in available in the public domain.

However, I do believe that the TAFESA was very well written, its provided clear and specific advice and in this article, I wanted to draw attention to how the audit model really does change how RTOs need to prepare:

How well do your staff speak VET?

"XXX did not use a marking guide as she relies on her professional knowledge when marking the assessments. XXX did not associate the marking guide to the Principle of Assessment Reliability to ensure that consistent competency decisions are made for all students regardless of who the assessor is conducting the assessor or where the student is located." - Extract from TAFESA ASQA Evidence Analysis

"XXX did not associate the knowledge requirements in the units of competency to the assessment process. This shows a critical lack of knowledge of the Principles of Assessment and Rules of Evidence, in particular, Validity. A student can only be deemed competent when they have been assessed as demonstrating the skills and knowledge requirements against all of the unit of competency requirements." - Extract from TAFESA ASQA Evidence Analysis

Generally reports will have a generic statement such as "The RTO did not provide sufficient evidence that its trainers have current knowledge and skills in vocational training (VET) and learning that informs their training and assessment. " -Taken from ASQA Report of Private RTO

So how well do your staff speak VET? Let's be honest, we have a hundred acronyms and even more vernacular, just as many industries do, often our trainers can speak their industry language but we don't invest in skilling them in VET speak. The Principles of Assessment (PoA) and Rules of Evidence (RoE) are arguably the two most important things a RTO needs to do and both are ensured, in largest part, by the assessor.

So how well do you as a trainer and assessor or do your trainers and assessors know the PoA and RoE? Well, for starters, they need to know what they are by rote and then have some understanding of how they are applied through your RTOs tools and processes. RTOs are required to support trainer and assessors with this through the provision of Clause 1.16 'The RTO ensures that all trainers and assessors undertake professional development in the fields of the knowledge and practice of vocational training, learning and assessment including competency-based training and assessment.' Pretty clear right? And yes, this includes your contract trainers also!

Do your trainers have the Cert IV TAE? And how did they get it?

It literally pains me to have to mention this...

"Insufficient evidence was provided at the time to confirm that the assessor held either of the following items on Schedule 1 at the time these assessments were conducted....

No other evidence has been provided to confirm that the trainer/assessor held the requisite training and assessment qualifications required by this clause at the time he conducted the assessments.

The email states that XXX complete the qualification in March/April 2016. It took over a year to issue him with the qualification. there were no contingencies in place for trainer on extended sick leave. Further, four competency conversations are not sufficient evidence to deem a person as competent for the TAE40110 Certificate IV in Training and Assessment."- Extract from TAFESA ASQA Evidence Analysis

So where do I begin?

  1. You should not be working with trainers who do not hold Cert IV! If you do, you need an assessor to cosign every assessment, this is rife with danger and not at all cost efficient. In the limited circumstances it has to happen, it should be for no more than a few weeks where you are actively recruiting!
  2. You need to issue quals within a month of completion unless payment is outstanding. (Minor in context but still)
  3. If you are issuing quals to your own staff, the standard for evidence needs to be even higher than if you are issuing quals to your students. Record everything! Moderate, moderate and validate! Have a clear internal process for issuing internal quals and how you will ensure that the assessment decisions are authentic and fair and free from bias on the base of the fact that you have peers assessing each other. In other words, avoid this at all costs!
  4. "Four competency conversations are not sufficient evidence to deem a person as competent for the TAE40110 Certificate IV in Training and Assessment.."In fact, twenty competency conversations are not sufficient. All quals, including the TAE past and present, are made up of skills and knowledge. You need to see them doing, get evidence of them developing and have a competency conversation to ensure they have the skills and knowledge... TAE is a high risk qualification, public and private providers out there offering discount RPL with just competency conversations as the gap assessment beware! You are doing the wrong thing.

Do your trainers hold the units?

"There was no evidence listed in XXX file that he had competency in the unit CPCPSN3023A Fabricate and install sanitary stacks as this was not a unit he undertook in his course CPC32413 Certificate III in Plumbing..."- Extract from TAFESA ASQA Evidence Analysis

"While the trainer profiles list each trainer’s industry skills and experience, the RTO did not provide any evidence to confirm that the RTO had verified each trainer’s industry skills, as listed in the profiles." - Taken from ASQA Report of Private Provider

There has been an expectation for a while now that RTOs map trainer competencies to the unit level. Actually, in 2017, we have seen a majority of auditors take the stance that if you don't hold the unit of competency, you map to the knowledge and performance evidence. Effectively, you need to hold the unit or have an RPL kit done for it. This is particularly being pushed by TAC, refer to the PD session run by Stephanie Trestail, notes here.

Additionally, validating that the trainers hold the competencies has been seen more and more in 2017 also. So validating your trainers qualifications are valid needs to be part of your onboarding process in the same way that you check students qualifications before you issue a Credit Transfer.

Overall, RTOs need to understand that having a set of policies and procedures and a compliant set of tools is no longer sufficient to pass an audit. Like many state funding audits, it comes down to ensuring that what you say you do, you do. This means that the larger your organisation, the higher the chance something can go wrong, because you have to rely on people making the right decisions. Many RTOs respond to this by trying to dummyproof policies, procedures and tools. However, the student audit model means ensuring that staff really understand, especially trainers, so the only option is to invest. Invest in training your staff on current requirements, how to use the tools, how to follow the policies.

In 2018, if you want to continue to operate as an RTO, I have one key piece of advice for you. Act like an education institution, and educate your staff. Do what you say and say what you do.

Good luck and happy training to all in 2018, public and private providers alike.

Lauren Hollows
Lauren Hollows