Speaking ASQAneese – Part 2

 

This article is the second instalment of a three part article series on understanding the language of ASQAneese. ASQAneese is an important language in the lexicon of VET regulation. Whilst ASQAneese uses English as its foundation, it draws on the tones, stress and rhythm of high order bureaucracy and intonation from the planet Zorgon. ASQAneese is a highly unique language, and it is crafted to allow ASQA operatives within their social construct to communicate in secret whilst having the effect of confusing and stupefying other recipients. Unfortunately, those other recipients are usually training providers who rely on interpreting the ASQAneese for their sheer survival. The stakes could not be higher and in this article, we will continue to break down the questions that you can expect to receive in your next performance assessment so that you can respond with confidence.

If you have not yet had the chance to enjoy the previous article, I would invite you to do that first:

Speaking ASQAneese – Part 1 • Newbery Consulting

 

Ok, lets just recap a couple of key points that came from Part 1:

• When ASQA ask a question, they have usually already looked at and reviewed all the evidence you have already provided and all information that is internally and externally available to them.
• The question is always targeted at a specific clause or purpose and is usually motivated by some concern they have but have not yet specifically shared. All questions are loaded questions and are all aimed at either confirming or clarifying their preliminary audit findings.
• Always have a quick and high level response ready to go. Don’t worry about answering the entire question up front. The questions they ask are often simply too big. Just give them a high level answer and force them to think and ask a more specific question that is often easier to answer.
• Just answer the question. Don’t go beyond the question in your answer. Don’t give them any information they haven’t asked for. You might think it’s a moment to impress but you are just opening a can of worms that will be difficult to get the lid back on.
• Have a very detailed understanding of your policies and procedures and of your current state of compliance. Understand where your current practice is not aligned with your policies and procedures, so you are not contradicting yourself in your verbal responses.
• ASQA will literally take notes on everything you say and they will use this information as another point of reference in their evaluation of your compliance. Your comments and responses will be referenced in your audit report.
• Avoid making any claims or providing any verbal information that you cannot verify with some type of record. Remember that, after you get through explaining something the next question is always: Show me?

 

In the last article we looked at questions relating to training and assessment strategies, resourcing training and assessment, industry engagement and lastly assessment. In this article, we will focus on the following topics on which questions will be asked Trainers / Assessors, Continuous Improvement, and Governance. Remember, these are questions that I have observed Auditors from ASQA asking clients on numerous occasions and it’s clear to me they are literally reading the question from a script so it makes sense that you think about how you would respond to these questions.

 

Trainers / Assessors

 

Question: Can you talk me through the process for recruiting your trainers and assessors.

Interpretation: Let’s be clear, ASQA have no jurisdiction over your recruitment practices or your employment arrangements. Those aspects of your business fall under the jurisdiction of the Fair Work Ombudsman or the Fair Work Commission. What the question is really asking is: What process do you apply to verify the relevant competency and currency that the trainer requires to perform the job they are recruited for. The quick response to get to a more specific question would be “We advertise, we get applicants, they submit the documentation according to the ad requirements, we review this information and narrow the selection down to the more suitable candidates, we interview these candidates and verify their credentials in the process. We would then select candidate and offer them the position”. The next question is likely to be the next question along in this article or they might ask about whose responsibility it is to prepare relevant trainer records such as training matrix, professional development plans, about the induction process and how you bring the trainer up to speed with the quality arrangements in your organisation. Remember that it is an obligation of the standards for the organisation to inform the trainer of any relevant legislative obligations and also the arrangements the organisation has in place to comply with these. This usually might be demonstrated by some type of employment induction record that specifically identifies the topics or information that were included in the induction process.

 

Question: How do you verify the competency and currency of your trainers and assessors?

Interpretation: This is very common question. It often relates to something that the auditor has observed in the training records that you have already provided for review. Most people will think that this question is about how you verify the qualification and competency records the trainer presents during the recruitment process. I guess it is about that, but it is also about the process you go through to align the vocational competency that the trainer holds with the competencies they are nominated to deliver. I would argue this is the primary purpose of the question. Regarding the document verification aspect of the question, you can explain that you will check the qualifications and competencies issued against a USI transcript (this is only useful if the qualification was issued after 2014). You can also contact the issuing organisation to verify the training products that were issued, verify the training organisations details and scope of registration at the time against the national training register, et cetera. These are few and more common ways of verifying competencies issued. I would always recommend that you record the verification method and date and by who on the document prior to retaining it in your trainer records.

In relation to verifying the trainer’s vocational competency according to the units of competency they are nominated to deliver, this is a huge question which I can sum up for you but, I would recommend that you read the following article Equivalent Vocational Competency. The quick answer is that you firstly identify the units of competency the trainer already holds which are directly equivalent to the units of competency to be delivered and you record these in your training matrix. Next, you identify the units of competency the trainer is nominated to deliver and which they do not hold equivalent units and therefore will be relying on presenting evidence of equivalent vocational competency. This is where you really get to the guts of the question because, what they are really wanting to know is what process you apply to undertake a mapping of the trainers past industry experience and related education training to come to the decision that they are sufficiently competent to deliver the units of competency which you have nominated them for. Remember that, ASQA are trying to determine how you satisfied yourself that the trainer was sufficiently competent. This evidence normally needs to be very detailed and identify in the trainer’s very recent vocational experience how they routinely perform the tasks outlined in the units of competency. Remember that the definition of “current industry skills and knowledge” includes a requirement for “industry experience” and I would argue that when you are trying to demonstrate equivalent vocational competency, industry experience is the most important factor. If the trainer cannot provide verifiable evidence that they have current industry experience performing the tasks outlined in the relevant unit of competency, then I would not nominate them for the unit. You would usually document this evidence of industry experience, relevant education and training, referees, employment experience, et cetera in a competency mapping document. It is quite important that this information reflects the requirements of the unit of competency at least to the element of competency level. I find that it is much better to collect this information through an interview with the trainer then to expect that they will provide you the level of detail you require. They will not. Organise an interview and go through each unit of competency and ask lots of questions.

 

Question: How do you ensure that trainers maintain their currency?

Interpretation: Before you answer this question, you need to know what your policy and procedure says. You also need to know what the state of your trainer currency evidence is. Does your policy that you have already handed over to ASQA require the trainer to participate in a minimum number of currency activities per year? What type of currency activities does the policy require? Does it require currency related evidence in relation to the trainer vocational skills and knowledge and what about their training and assessment skills and knowledge? How do the current training records (which you have already provided to the auditor) compare with the requirements of this policy? Your answer to all these questions is going to heavily influence how you respond. The important thing is, don’t contradict your own arrangements.

 

I’m not going to try and provide some benchmark answer for this question because literally the options are too broad. I do have a couple of key points to make:

• Evidence that the trainer is still carrying on work in industry even on a part time level is literally the strongest evidence of industry currency that you can get. This might be demonstrated by a letter from a current or recent employer. If you are requesting this, it’s good to request that they provide an outline of the type of duties the person performed and if possible, even get a copy of their duty statement. You can use this information not only for currency but also your equivalent vocational competency mapping.
• Evidence of vocational currency secondary to actually still working in industry might include things like, participating in industry professional development, participating in industry networking groups, undertaking workplace visits, staying abreast of industry developments by reading articles, work shadowing, maintaining industry memberships and licences, et cetera.
• Evidence in the form of the CV or work references of the trainer’s amazing experience as a “trainer” does not provide evidence of vocational currency or competency. I see evidence from clients that trainers have been bouncing from one college to the next for the last 15 years as a professional trainer. None of this experience contributes to demonstrating vocational currency. I can tell you that literally, ASQA do you not care that your trainer is the most experienced trainer in the world in whatever skill they have. If they haven’t recently worked in industry or can provide other fundamentally strong evidence of industry currency, it’s not going to fly. Clients say to me “but he teaches this stuff every day”. ASQA do not care. I often ask the client to get the trainer to rewrite their CV as though they are applying for a job back in industry and need to demonstrate their vast “industry” experience, not trainer experience.
• It’s worth noting that there is no mandatory requirement for industry related professional development. Yes, industry professional development helps with the trainer demonstrating their industry currency but there are many other ways of doing this. The only specific mandatory requirement for professional development relates to clause 1.16 where the trainer needs to demonstrate that they have participated in “ongoing professional development relating to vocational education and training including competency based training and assessment”. As a general recommendation, I recommend that the trainer completes about 3-4 professional development activities per year. I would also just reinforce the point that these professional development activities need to relate to delivering training and undertaking assessment. I make this point because I often see client’s trainers have participated in “compliance” related training which is not strictly about delivering training or undertaking assessment and I would usually advise the client that this does not help to satisfy clause 1.16.

 

Question: Can you tell me how you self-assure your trainers and assessors meet and continue to meet the vocational currency and training and assessment currency?

Interpretation: We had a number of questions like this in part one which relate to your arrangements to verify or validate something has occurred in accordance with the policy and procedure. What quality controls do you have in place to confirm that the trainers and assessors continue to meet the requirements of demonstrating currency in both their vocational and training assessment skills and knowledge. Of course, the answer to this will be based on your own internal arrangements. You need to remember that the national regulator expects that these trainers meet this requirement all the time. So, taking that into account, doing a random selection sampling of trainer records once a year is not really going to cut it. The answer needs to be a combination of both proactive strategies combined with quality assurance to monitor that policies are being complied with and records are being maintained. Proactive strategies might include applying a rigorous professional development calendar and making it mandatory that trainers attend. This might be a combination of both internal professional development and external professional development. Putting trainer professional development and compliance as a standard agenda item of management meetings is also a good idea. It’s always on the agenda and top of mind so it’s not something that falls into the background and doesn’t get complied with. Putting in place some type of incentive for trainers to comply with minimum currency evidence requirements is also a good idea. This could be financial, or material or recognition based.

In terms of “self-assurance”, we are really talking about things like trainer record review checklists and processes for undertaking these reviews on a regular basis. I wouldn’t recommend anything less than every six months. I would also recommend that this includes a sit down meeting with the trainer to go over these records to jointly identify the items that are outstanding which they need to follow up and provide within a defined timeframe. I would recommend doing this in March and October to avoid the end of the year crush. The outcomes of these reviews should be centrally recorded and reported back to the management meeting to make sure that they stay on the agenda and are rectified or the trainer is taken off the books. I totally understand that trainers are a scarce commodity. But, a trainer that does not comply with your requirements is a liability to your organisation. If you have a trainer like this, you either need to performance manage them to fix the problem or manage them out of the organisation and make them the problem of your competitor. Maintain evidence of these periodic reviews on the training records and make sure you keep accurate and well organised trainer records that are easily accessible. So, you can see that this “self-assurance” arrangement is multifaceted. It includes proactive strategies to prevent the problem in the first place. It includes policy arrangements that require periodic review, forms and checklists to conduct the review in a consistent way and finally, feeding the outcomes of the review into the management or continuous improvement process so that they are centrally managed.

Your immediate response might be something like: “Sure, we have policy arrangements that trainers are expected to comply with. These specify minimum requirements regarding the evidence of trainer currency. We provide a program of professional development activities to assist with this and we undertake regular trainer record reviews using established checklists to confirm that trainers are maintaining their currency. The outcomes of these reviews are managed in consultation with the trainer and within the management meeting”. The auditor will then ask a more specif question.

 

Continuous Improvement

 

Question: Can you talk me through your arrangements to apply continuous improvement to your training and assessment.

Interpretation: OK, let’s just keep in mind that when they ask this question, they already have a copy of your continuous improvement register, continuous improvement policy, your assessment validation schedule and records, your complaints register and policy, industry engagement evidence, et cetera. Obviously, your answer will be based on your own arrangements and how confident you are that your organisation is systematically applying continuous improvement.

Remember that, fundamentally continuous improvement is a very basic process of collecting information on how your training and assessment is performing and using this information to identify and act on opportunities for improvement. Simple. Of course, there are lots of other bits and pieces that sit around this such as some type of information management system to record these opportunities for improvement (this could be a register in a word document) and a management function to coordinate the implementation of improvement activities. So, when you get asked a question about your “arrangements” to apply continuous improvement think, process (PDCA), information collection, management coordination and information management.

Most of the time, this question arises because the auditor has identified something in the documentation that you have already provided where it is apparent to them that there is some type of breakdown or failure in your continuous improvement arrangements. As an example, they may have identified that the outcomes of an assessment validation were not recorded in your continuous improvement register or, maybe it was recorded but these improvements were not acted upon. That’s a classic. Maybe your industry engagement evidence identified some opportunities to customise the training to make it more relevant to industry but there was no record of this in your continuous improvement register. Maybe the continuous improvement register did identify improvements that needed to occur to assessment, but in the review of the sample assessment tools, it is not clear that these improvements were implemented across all assessment tools. Maybe there is a continuous improvement item in your register relating to a training and assessment strategy that suggests improvements were acted upon in Aug 2022. Logic would dictate that this would have led to a revised version of the strategy, but the strategy you provided as evidence appears to be in version 1.0. So, either your document management and version control are not working or your continuous improvement arrangement are not working. You see my point. They have identified something that appears to be a non-compliance with clause 2.1 and they are gathering information to verify how systemic that non-compliance is.

Continuous improvement really sits at the center of the entire RTO operation. I guess the take home message here is, have a good understanding of the components that make up your “arrangements for continuous improvement”. Make sure that your policy and procedure on continuous improvement supports these arrangements or alternatively adjust your arrangements to align with your policy. Most importantly, before you hand over any continuous improvement register, make sure this is up to date and in full alignment with other documents you are handing over and outcomes that may have emerged from assessment validation, industry engagement, complaints and appeals, et cetera.

Just one more little side note here. Last year we had a client going through their renewal of registration audit and in the process of this the auditor wanted to interview some trainers. One of the trainers was being very helpful and in response to a question about whether the trainer had access to the required equipment and resources, the trainer informed the auditor that they had communicated requests for additional equipment to management on several occasions and they were informed that it was raised as a continuous improvement. This one piece of information had a cascading effect on the audit. The auditor raised this at the management meeting and wanted to know why there was no record of this in the continuous improvement register. It also alerted the auditor to some deficiencies in the resourcing of training and assessment. Now, clearly these things need to be addressed and I’m not suggesting otherwise but, the point I would make is that, this process of auditing is not simply documentary. Everything that you say, or the trainer says or anyone that the auditor talks to, gets recorded and will be used to either verify or not your compliance.

If I were to provide a high level answer in response to this question it would go something like this: We actively collect relevant information that allows us to identify opportunities for improvement in our training and assessment. This includes information such as feedback from trainers, outcomes of assessment validation, feedback from students and outcomes from our assessment quality control, as examples. These outcomes are reviewed and where relevant are referred as an opportunity for improvement to the management meeting where they are considered and if warranted are created as improvement actions which are acted upon as part of our continuous improvement process. The auditor will then ask a more specific question which is actually the basis for their concern.

 

Question: What data and information do you collect to monitor the quality and compliance of training and assessment?

Interpretation: This question relates to the “Check” step in PDCA. The question is asking what your arrangements are to collect information to identify opportunities for improvement in training and assessment. The obvious items are, assessment validation outcomes (1), outcomes of industry engagement (2), survey feedback from students (3), feedback from trainees and assessors (4). Obviously, there are lots more information sources such as outcomes from complaints or appeals and particularly when we start thinking about the next question which relates to self-assurance practices. But, these four are really the common information collection sources that inform the improvement of training and assessment and if you are not systematically collecting this information and feeding it into your continuous improvement model then you need to start straight away. I know that some of these information items are easier to collect than others. Of course, trainers are an endless source of suggestions and feedback! 😊Getting feedback from industry is like getting blood from a stone. We all realise this but, ASQA exist in some fantasy land where apparently employers are falling over themselves to donate their spare time to help the RTO to improve their business.Getting students to complete feedback surveys is difficult and, in most cases, they will complete it as a tick and flick exercise and don’t offer genuine feedback. Every training organisation in the country struggles with implementing assessment validation and when they do genuinely identify useful outcomes from validation, these are not implemented consistently across all training products. So, I totally realise that even though we can identify these four specific information sources that, it is still not easy, but this is where we need to focus. If you can focus on just these four items, you will have a good story to tell in relation to what information you are collecting to monitor the quality and compliance of your training and assessment.

I would provide an immediate response something like: “Sure, as you are aware, we undertake a program of assessment validation which results in outcomes that inform our continuous improvement. We implement a regular program of seeking feedback from both industry and students on their satisfaction with the training and assessment being delivered and we also have an arrangement to collect feedback or suggestions from trainers. All these item’s feed into and inform our continuous improvement”. From there, the auditor is likely to then ask for some examples in relation to each of these items which you should have ready to go. A big part of demonstrating how you are reacting to opportunities for improvement that result from this information collection is the paper trail. My big suggestion is that you have a basic document that might only be one page called a “Continuous Improvement Record”. It doesn’t matter where the opportunity for improvement or suggestion comes from, it goes onto the Continuous Improvement Record which is centrally collected and used to discuss these opportunities for improvement at the next management meeting. These records should be retained as evidence. If it was agreed that the opportunity for improvement was valid and needs to be acted upon, then it goes into the continuous improvement register where someone will be allocated responsibility to respond and will update the management meeting of progress at a future management meeting. And around we go.

You see, when the auditor asks for an example, you can blurt out the best story possible about how the trainer provided this awesome feedback which you acted upon to improve your awesome training and assessment arrangements, but the next question is: Show me? Having continuous improvement paper trail is a great way to show how an opportunity for improvement first commenced and where the information was sourced initially that informed the opportunity for improvement. Another quick suggestion in your continuous improvement register is to create a column with some pre-designated drop down options that relate to the source of information relating to each opportunity for improvement. These might be Validation Outcome, Industry Feedback, Student Feedback, Trainer Suggestion, as an example. Having this column particularly in a spreadsheet will allow you to sort the improvement actions according to the information source column. This is useful when the auditor asks you for specific examples relating to opportunities for improvement resulting from say, industry engagement, as an example. Remember that, improvement cannot happen without collecting information that identifies something that needs to be improved. Focus on the big four and make sure you have a paper or digital trail to demonstrate how you acted upon these opportunities. You have got this!!

 

Question: How have you embedded self-assurance practices and continuous improvement into your operating model?

Interpretation: This is such a big question. Classic ASQAneese! I love how ASQA throw these big words around like “self-assurance practices” when neither they nor their auditors really understand what this means. Do you remember back in 2020 when ASQA made all of this hoohha about promoting “self-assurance”. They made all of these commitments around all the guidance and support they were going to provide to assist the sector with implementing arrangements for self-assurance and in reality, they have done none of this. This would have to be one of the biggest policy embarrassments that I have ever seen in my 20 years involved in VET regulation. Basically, they produced a graphic that identified continuous improvement around the outside of the circle and “quality outcomes” at the centre of the circle (mind blowing emoji insert here) and since then, they have done nothing. If you sense that I am just a little bit annoyed about this, you are right. Whoever had carriage of responsibility for the implementation of this self-assurance model at ASQA should reflect on the fact that it amounted to nothing because the job was not finished. Ok, just had to get that little rant out, now I am done!

So, self-assurance practices. I would highly recommend an article that I wrote back in Aug 2021 on RTO self-assurance (Click). In this article, I talk about a systems approach to self-assurance where you combine assurance coordination through your management team meetings, implementing a calendar of assurance activities throughout the year and focusing on getting right local assurance actions working. It’s all explained in the article, so I won’t try to re-explain here. I am going to assume that all of you are implementing some form of self-assurance practices. You may not immediately recognise it as this but in my experience, everyone is undertaking some type of “self-assurance”. What are we talking about? We are talking about the steps you have built into your operation to make sure that things happen. One of the very early examples of this that I noticed when reviewing a client’s enrolment arrangements was a simple administrative checklist the team in the office had developed and would staple on the inside of the student record. This checklist was implemented to ensure that throughout the student’s enrolment lifecycle that all the relevant documents were collected and verified and important steps were completed. Great stuff! We are talking about things like the collection of funding eligibility records, verification of the USI, training plan approval, resources issued, trainer allocated, orientation complete, LLN assessment complete, et cetera, et cetera. What function is this checklist performing? It’s performing lots of functions but primarily, it provides a mechanism to achieve administrative handling consistency regardless of whether you have been in that job for three years or for three weeks. It is reducing (not eliminating) the potential for important steps in the process to fail because, it’s in the checklist and if you just follow the checklist, you will be ok. The checklist includes the sum of corporate knowledge about what is required in the collection, verification and retention of student records to support compliance. This is a great example of a self-assurance practice. In our model of a Systems Approach to Self-assurance this is what we would identify as a “local assurance action”. It’s an action that an individual or a team completes to make sure that things are happening the way they are required to happen. Here are some other examples:

• Process and checklist to review a training and assessment strategy before it is approved and implemented.
• Process and checklist to confirm that sufficient equipment and resources are available for delivery of a training product.
• Process and checklist to undertake pre-assessment validation of an assessment tool to ensure it complies with the requirement of the training package.
• Process and checklist to review completed assessment before it is approved and reported in the student management system.
• Process and checklist to undertake post-assessment validation to ensure that assessment is being implemented as designed and according to the principles of assessment and the rule of evidence.
• Process and checklist to review a trainers recocords for competency, currency, licencing, clearances, professional development, et cetera.
• Process and checklist to review marketing material for compliance before it is release to the market.
• Process and checklist to confirm all training package and administrative requirements have been met before any AQF certificate is issued.

The second part of the question is asking about your continuous improvement arrangements and of course, outcomes identified through self-assurance should feed directly into your continuous improvement arrangements to ensure that these opportunities for improvement are acted upon across your operation. I would strongly advocate a fortnightly management meeting with a set agenda which includes reviewing your continuous improvement opportunities and actions.

Before you can answer this question, I guess you need to consider what you are doing in the way of self-assurance. Some of you may not be doing much at all and if that is the case, this should act as a prompt to get moving. As I have said a number of times in this article series, these audits are heavily focused on governance and self-assurance so if your training organisation is currently running on ad hoc and undocumented arrangements, it is time to tighten things up and think about implementing systematic self-assurance arrangements. I would recommend following the steps in our article A systems approach to RTO self-assurance.

 

Governance

 

Question: Can you talk me through the systems you have in place to ensure the provider’s business objectives and risk management strategies align with the Standards for RTOs? Seriously, read this one twice!

Interpretation: This is one of the most bizarre questions I have ever heard asked in an audit. This question really goes to the core of why I came up with the concept of ASQAneese. I mean, I can certainly get my head around the question but, can you imagine being asked this question out of the blue in a management meeting and sitting there thinking to yourself, “What??”. I once said to an auditor during a meeting with the client, “Sorry can you just elaborate on exactly what you’re asking”. It became clear to me that the auditor didn’t really understand what she was asking either. After fluffing around for a minute she said “I am just wanting to understand the systems you have in place to ensure your business objectives and risk management strategies align with the Standards for RTOs”. If I could insert a crying-laughing emoji here, I would. She just went back to the script because she didn’t know what else to do or say. Probably a good strategy in the circumstance.

OK let’s break it down, when we are talking about business objectives these can be different for different types of organisations. If you are a Community College, your objective is to maintain and grow your services to the community to support community skilling needs whilst at least covering your operating costs. If you are a for profit business, your objective is to deliver on the service you have promised your client and ensure that students get the skills and knowledge they need whilst trying to make a profit. So, when they ask about “business objectives” I would just consider this at a very high level. As an example, you might identify that your business objectives are to deliver high quality services whilst maintaining a healthy viable business, simple.

Now, “risk management strategies” in this context is complex to consider. The question assumes that all RTOs use risk management strategies as a basis for the management of their business risk and their compliance risk. Of course, it is a stupid assumption. Some might say wildly optimistic. I have had a long involvement with risk management. I have written policies on risk management; I undertook project to analyse the opportunities in the national training system to consolidate the risk management units across all training packages, I delivered a national workshops series to RTOs for years on using risk management to manage compliance in an RTO. I understand “risk management strategies” and I also understand that it is extremely rare to see any RTO actively using risk management as the basis for managing alignment with the Standards for RTOs. At the risk of appearing condescending, the problem is that “risk management” as a planning strategy or analysis framework is beyond most people’s capacity to fully utilise. Most people get confused in the subjectivity of allocating a likelihood and consequence and cannot see the forest through the trees when identifying treatments or managing residual risk. Sadly, I love that crap, but it is a hard push to convince the masses of its utility. I occasionally strike the odd “systems thinker” and they get it but, these people are rare. Now, overlay that reality with this crazy expectation that ASQA has that you are all using risk management strategies to align with the Standards for RTOs. To borrow a pun from one of my favourite movies “Tell’em their dreaming”. It is noteworthy that risk management features in the draft proposed RTO Standards that were released for comment in Oct 2022 including the specific requirement: “to identify and manage risks to the achievement of the outcomes described in the Standards”. It is likely that it will be a feature in the new Standards for RTOs when they are released.

The crux of this question is what I commonly call the “quality vs efficiency conundrum”. If you read the question it is basically asking, how do you manage the tension between your business objectives whilst staying compliant with the RTO standards. This is a conversation I have with clients virtually every day trying to help them navigate how they have their services structured to be able to compete in the marketplace whilst maintaining their compliance with the standards. Of course, this is usually managed through good judgement and risk versus reward consideration. Let’s consider an example. You are planning the delivery of a new skill set and your market analysis has identified others delivering this skill set in a very short duration. Question. Do you decide to meet the market and deliver the course in a similar timeframe to your competitors, or do you deliver the course in a timeframe that is more consistent with quality training and assessment and try and differentiate your market offering through a more quality based approach and adding value in other ways? You also realise that there is a realistic ceiling on the amount the market is likely to pay for this course (regardless of the quality) and so delivering the course in a shorter duration will allow you to reduce your wages cost therefore hopefully making the course at least profitable. You know that if you go for the short duration, you will struggle to justify this to ASQA but you also realise that given the market capped course fee, you will not be profitable if you go for the longer duration. What do you do? I can answer that question maybe in another article but, you get my point in relation to the quality versus efficiency conundrum. That is exactly what this question is about.

Ok, so how do you respond to this question. For 90% of RTOs, the response will go something like: “We don’t formally use a risk management strategy in relation to managing the alignment of our business objectives with our obligations under the standards. I guess we do intuitively do this when we are making business decisions about the delivery of services, and we often need to balance those decisions with managing our compliance. We will often make decisions about adjusting the delivery of services to support our compliance and in some cases, we will choose not to deliver a service because we can’t otherwise compete in the market and stay compliant at the same time and that’s a decision we sometimes need to make. Our RTO registration and therefore compliance with the standards is a fundamental underpinning requirement of our entire business operation and therefore, our compliance with the standards will always take precedence over business opportunities and that means that we usually need to innovate and carefully choose our market offering to operate a successful business at the same time as maintaining our compliance”.

Far out! Did you see me thread that needle!! Look, it is a stupid question. The ASQA Dozen really outdid themselves with this one. I think in answering the question you just need to consider your business approach to managing that quality versus efficiency balance point. How do you balance your business objectives of maintaining a healthy profitable business with competing in the marketplace and delivering quality services in accordance with standards? There is a balance point right there in the middle that you all need to consider what your approach to this is and how you manage that risk. Once you work that out, thats how you anser the question.

 

Conclusion

In part three we will discuss further questions relating to governance, third party arrangements, marketing, and enrolment. I know these are monster articles to read but I appreciate your positive feedback. We love supporting the VET sector and it is clear there is I need in the sector to understand how to communicate with the national regulator particularly during one of these performance assessments. I hope these articles are helpful to you and I look forward to providing more interpretations of these tricky questions in Speaking ASQAneese – Part 3.

 

Good training,

Joe Newbery

Published: 22nd August 2023

Copyright © Newbery Consulting 2021. All rights reserved.

 

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