Casey and the VRQA
Flying home from Melbourne. I have just spent two very good days with a client of mine (Casey) in Victoria. Casey is about to become the youngest (28) RTO owner that I know of. I’m sure there are younger, but it is pretty rare.
It was a great two days. We have been going through the final preparation before her initial registration audit which is scheduled in two weeks. It has been a long process and I am just amazed at the slow pace at which the Victorian regulator moves. There used to be guidance on the VRQA website that quoted an application timeframe of 3 months (it has now been removed). We did have a minor hick-up with the Victorian financial viability assessment (toughest in Australian by far!). But, other than that we have had evidence ready to go when it was requested. Today, we are coming up on 7 months! It is difficult to imagine how industry productivity is being supported with a choked regulatory system that is not able to process applications in a timely manner.
I don’t blame the regulator. They are doing their best to work within a system that has been bureaucratised over and over by successive governments. I have worked as a contract auditor within a number of regulators (not the VRQA) and despite all the rumours these are generally very good people working hard to be responsive and to maintain the integrity of the National Skills Framework. Trust me, it’s a tough gig. We should all buy them a drink! VET regulation is a 80/20 science. They spend 80% of their time regulating 20% of the RTOs who are not doing the right thing.
I am constantly impressed by Casey’s enthusiasm and hard work. She has followed my advice to the letter and I am so proud of how she has developed her resources and taken ownership of the RTO system. Her commitment to quality and attention to detail just blows me away. It is difficult to prepare for an audit, especially an initial registration. For those that do not know, in Victoria they have a compliance requirement that sits over the top of (or along side, I’m not sure) the AQTF. These are the VRQA Guidelines released in 2009 and they are very prescriptive. They really do not require “interpretation” and serve to define the standard of arrangements an RTO should have. My view when they were released in 2009 remains the same now. If you prepare a quality and detailed operation, the VRQA Guidelines take care of themselves.
There are a couple of funny requirements . These are: Plagiarism and Cheating arrangements, the need to establish an academic committee, restricted hours of operation, mandatory mapping (even to Employability Skills! Why?) and a few other things. By in large I think they are fine. They don’t worry me as we have always got the detail right with these applications. I do have a little objection to the requirement for mapping. I think the prevalence of mapping has overshadowed to need to actually design assessment. People tend to develop the assessment through a process of mapping making sure that they have left nothing out! This often leads to a minimalist outcome that bares no relationship to actual workplace tasks. I think mapping is a trap for those learning and developing their skills in assessment design. If it has to be done, do it at the end as a component of the assessment validation. Why do auditors ask for it? Because it is easier for the auditor to check that the entire unit has been covered. NARA had a great approach to this. Their policy stated that, there was no need for the RTO to provide mapping to demonstrate they are meeting training package requirements. The NARA auditor was expected to mentally map the assessment materials against the unit to determine the assessment validity. “Way to go NARA”!! Alas, NARA is gone and we now have ASQA. I wonder what their approach will be?
Anyway, the reality in Victoria is, what it is. Mapping is needed, even to employability skills! That is a whole another discussion for another time. And for Casey, “You go Girl”. I won’t wish you luck, because you do not need it, your hard work and good management will see you through.
Joe Newbery