Speaking ASQAneese – Part 3

 

This article is the third instalment of our article series on understanding the language of ASQAneese. Over the last 12 months ASQA has significantly changed its audit model to utilise audit meetings to interrogate providers with scripted questions that they provide no advanced warning of. Receiving these questions without any prior notice can be unsettling for the entire audit and impact the audit outcomes. In this third instalment, I finish off talking about governance with the remaining governance related questions which follow on from the previous article. I also go on to cover questions related to marketing and learner support services. At this stage, there is no plan for a fourth instalment of ASQAneese although, this is such a rapidly changing space that the need may present itself. I will be guided by you. I do hope that you find this article help as part of our efforts to support the VET sector. It has been fun bringing it to you and I am most appreciative of your wonderful feedback.

 

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

 

Speaking ASQAneese – Part 1 – Newbery Consulting

Speaking ASQAneese – Part 2 – Newbery Consulting

 

Governance (continued from Part 2)

 

Question: Can you tell me about what process you use for internally reporting any identified non-compliances, and how does the executive management engage in the resolution process?

Interpretation: I remember when I heard this question asked for the first time. It was during a management meeting with a client of ours that was in the middle of a renewal of registration audit. At this stage of the audit, the regulator had already identified a number of fairly significant issues. Of these, it included evidence that non-compliant assessment identified through assessment validation had been rectified for the sampled unit only and these improvements had not been implemented across other units within the same qualification. This does raise genuine questions about the internal governance arrangements and how involved the executive team are with quality assurance activities. We need to always remember that under the legislation (NVR Act) the executive officer is ultimately responsible for everything happening within the RTO. It all comes back to the executive officer and how they execute their vested authority. Some executive officers are extremely detached from the operation and have basically delegated compliance to someone they have appointed. This of course is a very poor strategy. In their head, they think they are “managing” the organisation, but this is not management. I don’t care how big or small the training organisation is, using mechanisms such as compulsory management meetings and mandatory internal reporting, the executive officer should be able to maintain very good situational awareness over the organisation’s governance and compliance at all times.

So, the underlying question here is, exactly what are the internal reporting arrangements, how do you get together and discuss opportunities for improvement (including non-compliance) and how involved is the executive officer in the process? Of course, the simplest and most effective way of internally reporting opportunities for improvement is to have a continuous improvement (CI) report. This can be as simple as an electronic form that is completed by the person identifying the CI that pushes the CI to the management meeting for consideration. This must be a regular management meeting that has a standing agenda which includes consideration of opportunities for improvement. This is the best way to ensure that the executive officer and senior management are fully aware of and engaged in responding to opportunities for improvement or any non-compliance. Obviously, your answer needs to reflect your current arrangements because, anything you say will lead to the next question being, can you provide me some evidence of that? If you say that you hold regular management meetings, the next question is going to ask for evidence of management meeting minutes or a record of these management meetings. The way the question is worded, gives the impression that it is much more complicated than what I have described. I have seen clients get this question and literally sit there like a stunned mullet. They are thinking in their head “internally reporting, non-compliances, resolution process, do we even have a process for this?”. This question is classic ASQAneese. The question stuns you in the moment and you will notice the corners of the auditor’s mouth slightly curve upward as they hold back a full blow smile in satisfaction with how they delivered this stupefying question. Remember, always take it back to basics and do not get thrown by the question.

If I were answering this question, I would say: “Absolutely, we use our continuous improvement arrangements to document and report opportunities for improvement including any non-compliance that is identified. These are documented within a continuous improvement report which is provided to the management meeting with the executive officer as the meeting chair. These opportunities are discussed within the team and action items are identified and recorded within the continuous improvement register which is used to allocate responsibility and follow up implementation”.

Now, if you don’t have these types of arrangements in place then hopefully you have something similar, but I cannot overstate the importance and value of having some type of basic reporting arrangements and holding a regular (I recommend every two weeks) management/team meeting. Having a regular management meeting with a standing agenda including important items such as learner support, continuous improvement, legislative changes, compliance, training / assessment delivery, administration, learner communication, safety, complaints or appeals, as well as all the other normal thing is basic 101 compliance and governance. The management meeting and the CI process is like the hub of the wheel.

 

Question: How do you determine when it is necessary to inform staff and clients of any changes to legislative and regulatory requirements that affect service delivery?

Interpretation: I think this is a good question. It touches on two clauses within the standards that often fly way under the radar. These include:

• Clause 5.4. Where there are any changes to agreed services, the RTO advises the learner as soon as practicable, including in relation to any new third party arrangements or a change in ownership or changes to existing third party arrangements.
• Clause 8.6. The RTO ensures its staff and clients are informed of any changes to legislative and regulatory requirements that affect the services delivered.

Arguably, it relates more to clause 8.6 but there is no getting away from the obligation in 5.4 to advise learners as soon as practicable of changes to agreed services regardless of whether they are the result of a legislative change or simply changes that you have made. It is a requirement that most RTOs are not aware of, and it also has implications for appeals handling. You need to think of your response to this question in two parts.

The first part is staying informed of legislative changes and notifying these to the staff working within your RTO. How do you stay informed? All CEOs and/or those responsible for supporting compliance should be subscribed to all manner of newsletters including State and Federal legislation websites where you can subscribe for updates to legislation you are tracking. Other information sources such as ASQA, DEWR, Department of Education (Federal and State) of course Newbery Consulting any other trusted information source. That is the first trick to being able to notify staff of changes, is knowing about it. The next step it to have a forum to notify and promote these changes. Like all these important things, I think this should happen during your regular management meetings and most likely triggered by a continuous improvement report. It makes sense. Let’s take the recent Early Changes to the Current Standards for RTOs. This was a change to legislation that has an impact on how we may manage our trainer workforce. It needs to be considered in light of the policies that may need to be updated, changes to trainer recruitment practices maybe and supervision arrangements, etc. It makes sense that you look at the changes and, in this case, raise a CI report so that it can be discussed at the next management meeting. It is better to discuss these changes as a team and get everyone’s ideas about how you react. When you do put a notification out to all staff, you will be not only notifying them about the change but also, how it will affect your current arrangements. Everything should be channelled through your continuous improvement arrangements for that reason.

The second part is a little more complicated. If you read 5.4 and 8.6 in combination in respect to learners, you can see that is specifies that if you experience or are implementing changes, you must inform learners as soon as practicable. These changes include to legislation, ownership, third party arrangements and importantly, changes to the agreed services to be or being delivered. I often find myself in discussion with clients and we may be talking about a policy or the learner handbook and as a result of that discussion, the client has resolved to make a change. Lets say it related to their refund policy or learner support services. The client is ready to make these changes straight away and implement them immediately. But hang on. These changes to these policies or services will change the services that you have agreed with current learners. You cannot just change them on a whim. You need to think about how this may impact current learners. You also need to remember that clause 6.2 requires that you have “an appeals policy to manage requests for a review of decisions, including assessment decisions, made by the RTO”. So, if you make a decision that changes the agreed services being delivered (including the rights and obligations that govern those services), you have an obligation to inform the learner first and allow for your appeals period before implementing those changes. So, lets consider an example. If your appeals period is 28 calendar days and you want to change your policy on refund arrangements, you would finalise the change and then send a notification out to learners via email notifying them of the change and the date on which it will be implemented (in 28 days from the notification). Learners will know from the learner handbook about their right to appeal a decision. It is very rare that they will but at least you have afforded them that procedural fairness.

Ok, so you can see that whilst the question looks fairly simple, it has a lot of moving parts. I just need to recognise at this point that most auditors from ASQA do not understand this complexity themselves. The point is that if you can develop your thinking and understanding around this question based on these two clauses then you will be fine. Th auditor will either understand or be sufficiently discombobulated that it will leave them with no other option than to move on to the next question.

If I was going to answer the question it would be something like this: The first thing we do is monitor the relevant information sources so that we are aware of any changes. Any changes would be referred through to our regular management meeting using our continuous improvement process where it could be considered and then responded to. Any notification to staff members would be dependent on the consideration of the changes and if required notification would be provided as soon as practicable. Notifying learners of relevant changes to either legislation or changes to agreed services is a little more complex. Once these changes had been finalised, we would then provide a notification to learners and allow them a notification period of 28 day prior to implementing any changes. This allows learners to consider the changes and to exercise their right to an appeal if they choose to do so.

At this point the auditor will either say great and move on or they may ask you for some examples of how you have responded to recent changes.

 

Question: Can you talk me through your self-assurance process on issuing AQF certification documents

Interpretation: I have been doing a lot of thinking and talking about self-assurance in the last 2 years. Every since I published this article back in 2021 (A systems approach to RTO self-assurance), I have needed to constantly question myself and answer questions about what self-assurance is. I really need to publish an updated article to get all of these thoughts down in writing. But, I consider that a system of self-assurance within an RTO is made up of the following components:

Strategic level

• • A risk management approach to compliance management
  • Contingency planning

Operational level

• • A regular management meeting (assurance coordination)
  • A continuous improvement process
  • A calendar of assurance activities

Workplace level

• • Local assurance actions which involve activities that are:
    • Quality control activities;
    • Quality review activities; and
    • Compliance and administrative routines.

I identify the above to put my interpretation in context. The question relates to the quality controls that you may have put in place to ensure when you issue an AQF certificate that you have verified that adequate assessment has occurred (3.1), the certificate is in the right format and is authorised (3.2), the certificate is issued within the required timeframe (3.3), the learner has provided a verified USI (3.6), the learner has paid all of their fees (3.3), the units and outcome are all correct (7.5), etc. Your self-assurance process or quality control arrangement might be as simple as a policy which requires your staff to review and confirm all these things before a certificate is issued. You could also have a workflow diagram or procedure provided to relevant staff to remind them of implementing this quality control each time they go through the process or at the extreme end of intervention, you could require the team to complete some type of certificate issuance checklist. The level of intervention needs to be consistent with your operating context and the level of risk that you perceive in the process. Obviously, the risk can vary depending on how many certificates you issue, the quality of your assessment system, your enrolment and fee collection process, etc. Sometimes the level of intervention is informed by continuous improvement. You may choose to take the lesser approach of intervention by simply establishing a policy and providing relevant staff training on the policy. You might find during an internal audit or an internal self-assessment that regardless of this arrangement, errors have occurred that have resulted in certificates being issued that do not meet all the requirements. Your rectification or improvement as a result of this finding is to increase the level of intervention which may include implementing a compulsory checklist to be completed on all occasions. It is important to recognise that quality and policy arrangements all should be viewed with different levels of intervention depending on the context of operation of the RTO. Ultimately, this is where risk management informs the level of intervention. If you perceive that the risk is high and you are not comfortable with this, you would implement a heavier level of intervention. If you perceive that the risk is relatively low and you consider current interventions appropriate then you would leave the existing interventions in place.

There is definitely a need for a more deeper dive into self-assurance generally, but, for the purpose of interpreting this question and establishing an answer we need to recognise that your self-assurance process on issuing AQF certification will be informed by what quality controls you have in place and are applying and what your quality review arrangement is to identify where the process is not working and non-compliance is still sneaking through.

If I were to answer this question, it would be something like: We have an established policy and procedure on certificate issuance, this includes the process to verify the aspects relating to issuing the certificate before it is authorised. This is supported by an assessment quality control process that ensures we are holding valid evidence of the assessment undertaken in support of each unit. We also confirm that the learner has provided a verified USI, the learner has paid all required fees. This is recorded within a checklist that we use to systemise these checks. We also follow out procedure to ensure that the certificate is issued within the 30 days from the last assessment.

 

Question: In relation to your self-assurance in support of handling complaints, appeals, how do you identify an act upon corrective actions to prevent the reoccurrence of complaints or appeals?

Interpretation: I have seen this same question asked so many ways. What they want to know is, how do you reflect on the root cause of a complaint or an appeal to identify if there is anything within your strategies and practices that could be improved to prevent a complaint or an appeal of this type from happening again. I find when I am explaining this to a client, they can sometimes confuse this with the final outcome of a complaint or an appeal in regards to the actions you might take based on that specific complaint or appeal. This is not what the question is asking. This brings to mind the concept of treating the symptoms rather that the underlying illness or cause. Yes, we can come up with an outcome that everyone is happy with (or not) but this does nothing to get to the underlying problem to prevent the problem happening again. That is the part that ASQA wants to know about. It is a relatively simple response really but only if you have these arrangements. The answer is to establish a step at the end of your complaints and appeals handling process to complete a quick root cause analysis to identify any long term opportunities for improvement. If you identify these opportunities, they should be recorded into a continuous improvement report and referred to the regular management meeting for consideration and acted upon appropriately. That is really it.

Just a couple of other things about complaints handling whilst I am on a role:

• Complaints and appeals are separate processes. A learner or anyone can submit a complaint. If a complainant is not satisfied with how a complaint has been handled, they can request a review of the complaint by an independent person or body. This is not an appeal; this is simply a review of the complaint handling. An appeal is a separate process where a person can appeal a decision the RTO has made. If the person is not happy with the appeal outcome, they can also request a review. A complaint does not logically flow into an appeal. I see this confused all the time. You may not agree with me and that is ok.
• Do not be afraid of using the complaint handling process. RTOs seem to think that complaints are bad and it is good that we have an empty complaint register. I suppose that is true from a certain perspective, but complaints are also golden opportunities for improvement. It is important to recognise this. Sometimes we receive negative feedback from a learner, or an employer and we tend to deal with this informally and it never gets recognised. I would encourage you to record it through your complaint handling process which should result in output for the continuous improvement process. ASQA will think this is great. It is evidence of the system working.
• Use your complaint handling process to manage difficult learners or other stakeholders. From time to time, a client will contact me about some difficult learner who is not cooperating or is harassing staff after not getting an outcome they wanted. I am sure you have all experienced these. The client contacts me wanting advice on how to manage this leaner in a way that will be consistent with the standards and will be defensible if the learner runs off to ASQA. My solution is almost always to register the entire situation as a complaint yourself and handle (communicate) with the learner in accordance with your complaint handling procedure. This guides your process, timeframes, communication, review arrangements and ultimately the person’s options to seek a third-party review. It makes everything transparent and is documented. Do not struggle on “managing” these situations. Use the complaint handling arrangements to manage the situation according to a set of rules.

 

Marketing

 

Question: What controls do you have in place to verify the compliance of marketing materials before these are relied on?

Interpretation: This question is almost identical to the question on the self-assurance process on issuing AQF certification documents except it is about marketing. So, we are focusing on your quality controls that you have in place to check, review, validate the proposed marketing before it is released into the wild. The best way to do this is to establish a simple procedure (as part of your current marketing policy) that requires proposed marketing to be reviewed and amended if needed before it is approved for release. This should be supported by a checklist that reflects the requirements of at least clause 4.1. I also think that some elements of clause 5.2 are also relevant. This checklist should identify the marketing being reviewed and systematically checked-off against these criteria to confirm that the marketing is compliant.

Common problems with marketing include:

• It is not consistent with the training and assessment strategy
• Does not identify the training product accurately
• Does not include the RTO number
• Includes superseded training products
• Does not accurately describe the services to be delivered

Seriously, this is such an easy quality control to implement. If you do not have a marketing checklist in place at the moment, then implement one now and use it to review all of your current marketing. When you get asked this question you can confidently explain that you have a process for reviewing and approving marketing material before it is released. You can explain that you have a marketing checklist that you used to standardise this practice. You will obviously be asked to provide examples of recent marketing material that have been reviewed using the checklist. Perfect.

Just a couple of quick comments on marketing. I personally view marketing as part of the three pieces of information that make up the pre-enrolment information. These include the learner handbook, the course brochure, and the fee schedule. Now you may call these thing different names and you may even have a different structure but, these three items of information are universally consistent across most RTOs that I have ever engaged with. I view the course brochure (marketing) as the tool that informs the learner about the services to be delivered. So, all the information that is specific to a particular course will be in the course brochure. This means that it is not only items relevant to clause 4.1 such as RTO number and training product code and title. It will communicate details required by clause 5.2 including a description of the planned training and assessment, educational and support services, estimated duration, expected locations, modes of delivery, work placement, entry requirements, materials and equipment that the learner must provide, government subsidy obligations, etc. Obviously, all this information needs to align with the training and assessment strategy. Keep the learner handbook as more of a generic document that informs the learners about their rights and obligations. The fee schedule includes all the course fees, any additional changes the learner may incur, consumer protection information, refund arrangements and explain fee protection arrangements. The fee schedule is aimed at covering the requirements in clause 5.3. Some of this may also be in the learner handbook and that is ok. Together, these three items of information cover your pre-enrolment information obligations.

 

Question: Can you explain how you ensure your marketing material is accurate and reflects your registration obligations?

Interpretation: If the last question was about your marketing quality control, this question is about your marketing quality review arrangements. It is interesting that when you get into it with a client and you are both thinking and talking your way through these quality controls and quality reviews, it is sometimes not clear what the quality review would be. Marketing is a bit like that. Marketing gets published and it get updated but unless you are going to instigate some form of audit or review of marketing, there is not really any other way that it happens. Like other things we have discussed in this article so far, you need to determine the level of intervention to implement a marketing quality review. Remember that a quality review is checking that something that we have already released and are using is working, is fit for purpose or remains compliant. At the extreme end, some clients undertake a quarterly or half yearly formal review of their marketing. This will often identify many opportunities for improvement. The level of intervention should be informed by your compliance risk management plan. A lesser intervention would be to conduct a specific annual review of marketing or maybe even roll it into your annual self-assessment. I do think that at a minimum, an annual quality review of marketing is critical, and it is reasonable to do this during your annual self-assessment. Findings that result from this review should be raised as opportunities for improvement and referred to the regular management meeting to be considered and acted upon.

If I were answering this question, I would say: In addition to our marketing checklist that we used to verify that marketing is compliant before it is released, we also undertake an annual review of our marketing as part of our annual self-assessment. This review will look at our website and any digital marketing material that is released to learners prior to their enrolment. It will also consider any printable material and our social media. This review commonly does identify some opportunities for improvement where marketing material has fallen out of date with the current delivery arrangements and these opportunities for improvement are referred through to our regular management meeting to be considered and acted upon. These will be entered into our continuous improvement register where we will revisit these each meeting until they are completed and closed out.

If the auditor knows what they are doing, the next thing that will ask for is a record of your last self-assessment (if they haven’t already got it) and any records of opportunities for improvement relating to marketing.

 

Learner Support

 

Question: Can you talk me through how you confirm the learners have been enrolled in the appropriate training product?

Interpretation: This question is classic ASQAneese. You might bumble your way through answering this question just out of common sense but what the auditor is asking relates to clause 5.1 which says: Prior to enrolment or the commencement of training and assessment, whichever comes first, the RTO provides advice to the prospective learner about the training product appropriate to meeting the learner’s needs, taking into account the individual’s existing skills and competencies.

This clause serves a number of purposes. Firstly, it makes it mandatory that you systematically provide a perspective learner with access to pre-enrolment information either before they commence the course or before their enrolment is confirmed, whichever comes first. The only time when a commencement might come before the enrolment is during a very short course such as a day only course. This is where a learner may present for the course on the day and they have not yet enrolled formally. The first thing the training organisation does is provide them a briefing on the pre enrolment information and makes this information available prior to them completing the enrolment form. It’s not ideal to say the least but you would be surprised how common this is. Is it compliant? Sure, if the RTO can demonstrate that prior to the learner either commencing or completing their enrolment, they are provided with the relevant information. It is obviously far more common that a learner will complete enrolment before they commence and therefore the provision of the pre enrolment information either through a physical copy or through referral to an electronic copy must occur before the enrolment is confirmed. I always point out to clients that a learner completing an application for enrolment is simply an application and them signing the application document does not signify that the enrolment has been accepted. Usually, the enrolment is confirmed by the training organisation with some type of correspondence back to the learner to confirm that their enrolment has been accepted. This is the point when we can say that the learner is “enrolled”.

The other purpose that is served by clause 5.1 relates to the words “provides advice to the prospective learner about the training product appropriate to meeting the learner’s needs, taking into account the individual’s existing skills and competencies”. In a nutshell, this requires that you engage with the learner to determine if the intended course is suitable to their needs. ASQA interpret this to mean that you assess their language literacy and numeracy and determine the learner’s general suitability to enter the course. This is primarily aimed at making sure that we are not unfairly enrolling the learner into a course that is not suitable for their needs. A course may be unsuitable if the course level is beyond the learner’s entry level and capability, is not consistent with the learners demonstrated ability to study and where the learner may not meet the entry requirements. This could also relate not only to language literacy and numeracy but also their digital literacy particularly where the course may be delivered online or require advanced digital literacy skills. So, there are a couple of key points that you can take out of this. The first is that the national regulator absolutely expects that language literacy and numeracy assessment is happening in all occasions for all types of enrolments unless of course the training organisation has reasonable exemptions. It is reasonable to say that a learner who has completed a higher school certificate or has successfully completed lower level nationally recognised training may be exempted from needing to complete LLN assessment because they have previously demonstrated their ability to study. This is certainly not a policy within the standards, but it is a policy that our clients have successfully applied for many years. In all other cases and where you may have doubts, language literacy and numeracy assessment should be considered compulsory. Those in Victoria would also be familiar with the pre-training review process that is mandatory under the funding requirements of that State. The pretraining review looks more broadly at the learner’s education and vocational background and current experience also to determine their suitability for the intended program. This is  a very good practice and has spread organically into other States and Territories for that reason.

A common question that I get about language literacy and numeracy assessment which I might just deal with now before I move on. Is language literacy and numeracy assessment compulsory in short courses such as half day or a one day course? My blunt answer is, yes. I may not agree with it, and I have put the case to ASQA as hard as possible about why this is ridiculous, and they maintain a firm position that clause 5.1 does not differentiate between the course duration. Saying that, they are terribly inconsistent on applying this rule between different auditors and different providers. I have seen many clients where this has not been raised as a concern but every now and then we will get an auditor that wants to see a language literacy numeracy assessment for a learner entering say, a CPR course that is conducted over 5 hours. We have come up with some smart solutions over the years such as incorporating a simplified ACSF mapped, language literacy and numeracy assessment into the enrolment form. This has been a successful strategy that tries to find the balance between quality and efficiency that has been consistently found satisfactory by the national regulator. The new standards include more specific and increased requirements around engaging with learners prior to their enrolment so this is an area that we all just need to get very systematic about.

Ok, if I were responding to this question, I would say: We have systematic arrangements in support of our enrolment process. This includes providing very clear information about the proposed course prior to the learner’s enrolment. We also require the learner to complete an application form which collects information about their individual needs and prior education. For qualification enrolments, we also undertake an enrolment interview where we discuss the intended course and the learner’s suitability. Lastly, we administer a language literacy numeracy assessment for those learners that have not demonstrated prior study capacity to ensure that the course the learner is seeking to enter is aligned with their needs.

Something that I have not reminded everyone about for a little while between these different articles and it’s worth repeating again here now. Remember, do not try and tell your entire life story in your answer to the question. You should find the shortest possible way to specifically answer the auditor’s question and give nothing more. If the auditor wants more information, then it is their responsibility to ask the next relevant question. It’s important that you listen carefully to the question and only answer the question. Yesterday was a good example of where a client did not do this. I was doing a little rehearsal exercise with one of our lovely very long term clients preparing for a management meeting next week. I asked the client to talk me through the support services that they have established. The client went off on a completely different tangent talking about the entire enrolment process and how they identify the learners needs, yadda, yadda, yadda. I needed to pull the client up mid answer and point out to them that they are not actually answering the question. 20 years of being involved in VET regulation on both sides of the fence has well and truly taught me that you only ever specifically answer the auditor’s question with as little information as possible. You need to put the onus back on them to ask the next question. Most of the current auditors lack the experience to think on the hop and come up with the next question so they usually just accept what you have provided and move on. Obviously, you are prepared to fully cooperate with the national regulator and provide whatever information they request but it is their responsibility to request it. Do not do their job for them. By providing information beyond what the auditor requested, you also run a high risk of saying something that opens up a new line of questioning. Sometimes I sit there in the audit meeting on Teams thinking to myself “Far out! Stop talking!”. Just answer the question.

 

Question: How do you determine if learners require support services?

Interpretation: This question is essentially a repeat of the last question worded in a slightly different way. You may get either one or both. The answer is essentially the same.

But, this does present me the opportunity to talk about a recent trend and something you should take note of. About 12 month or so ago, I started to see instances of clients with non-compliance needing assistance where the regulator had made the RTO non-compliant for clause 1.7 for “failing to provide access to the educational and support services necessary for the individual learner to meet the requirements of the training product”. These instances related to where the client had arrangements in place for LLN assessment and in most circumstances using a third party testing provider (such as LLN Robot), but the regulator identified instances where this testing process had recommended LLN support, but this LLN support was never acted upon. So, the provider had implemented a very suitable LLN assessment process but had not followed through with support when the assessment process identified that support was recommended. It is notable that some of these third party testing providers do produce quite a detailed report on the type of learner support that is recommended to improve the learners LLN skills. This support is intended to be provided during the learner’s enrolment. Where this support is not implemented and no action appears to be taken, it is a very bad look for the training organisation. I suppose the take home message from this is, if you implement arrangements to identify learner support requirements, make sure that you have suitable capacity and process to act upon these findings and provide the necessary support. You should put a learner support plan in place and monitor the learner’s progress.

 

Question: How do you monitor the need for support services during the learner’s enrollment?

Interpretation: This is a recent question that has emerged during management meetings and application interviews within the last three or so months. As far as the questions go, I think it’s reasonable and it’s actually good for training providers to think about how they actually monitor the need for support during the learner’s participation in training. This question relates to Clause 1.7 which says “The RTO determines the support needs of individual learners and provides access to the educational and support services necessary for the individual learner to meet the requirements of the training product as specified in training packages or VET accredited courses“. How do you do this? I think it’s one of those questions that some training providers could answer very easily and have invested in systems to support monitoring the need for learner support. I think many training providers do this rather informally and it is predominantly led by trainers monitoring their learners progress and engaging with learners to identify when they may need more help than they are currently getting. This may not be necessarily written down or defined by policy but that is not to say, that it’s not happening. The problem with these informal arrangements is they often do not result in any documented communication. So, when you are seeking to demonstrate how these arrangements are occurring and provide examples of support that you have provided, it is often quite difficult and in most cases the organisation struggles to provide this.

If you do not have a current arrangement in support of this requirement then I would recommend that you develop one. This could be very simple by ensuring that it is part of the duties and responsibilities for those who engage with learners to monitor the need for learner support. There should be a process for personnel within the organisation to nominate learner support requirement to your designated learner support officer. If you don’t have a designated learner support officer, then you should appoint one straight away. This can be an existing staff member that you provide some appropriate training to, but it is generally not acceptable not to have someone within your organisation designated as the learner support person. Nominating a learner for learning support could be as easy as sending an email or completing a basic form and submitting this to the right person who will respond to this request by making an appointment to meet with the learner to further discuss their support requirements and go from there. I would also recommend that you have a basic learner support plan to document the learning support that is to be provided, to record progress and to schedule follow up sessions. I also generally recommend that clients maintain a record within the student management system if appropriate privacy protections are in place. You should ensure that there is very clear information provided within your learner handbook that informs the learner of the support services available and who to contact if they need support. Your learner support officer should have access to information which guides them in providing support both internally within the organisation and also providing a range of options to refer the learner to external specialised support services where this may be required. You need to make it clear to the learner if this will result in any additional cost. This is an area which is only going to get more focus as we progress particularly into the new standards which include a new requirement in relation to supporting the learner’s welfare.

If I were answering this question, I would say: I think first and foremost we have an expectation that if the learner needs support that they will reach out to us. We inform them in the learner handbook which is provided prior to their enrolment of the support services that are available and who to contact if they require support. This information is also reinforced that during their orientation. The person working with the learner during their training and assessment is the trainer who has a responsibility to monitor the learners progress and to refer the learner for additional learning support if this is considered necessary. They obviously do this in consultation with the learner. Our learner support officer has access to a range of support services that we can provide both internally and by referral to external specialist support providers at the learners on cost. We can put a learner support plan in place that identifies the support to be provided, the progress made and identifies plan for scheduled learner support sessions. We maintain records of learning support within the learner support plan and within the student management system on the learner’s profile.

 

Conclusion

Before I wide up, I just want to reinforce a point that I made in Part One of this series. In order to answer any of these questions and not contradict your own policy, procedure and practice, you need to fully understand your current policy, procedure and practices and take these into account when preparing to answer these questions. You might provide the best answer possible but, if this answer contradicts you own policy, it is a very bad look. Remember that at the time you are sitting in this meeting being asked these questions, the auditor has already reviewed your relevant policies and procedures and all of the evidence that you have already provided. They already know what your policy says and they also have already started to form a view as to your compliance based on all of the evidence. The reason they are asking the question is to confirm your understanding and awareness. I cannot overstate the importance of having a very comprehensive understanding of your own compliance. Put it this way, when the auditor asks you about something they have identified as non-compliant, it should not be news to you. You should be all over it and already in the process of fixing it. You need to be in front of where the auditor is focusing.

This is my final article on ASQAneese, maybe. I want to move on to other important priorities. I hope these articles have been helpful to you and I look forward to publishing more articles and information in the future. To be honest, I have an endless number of topics that I could write about. There is barely a week go by when I am assisting a client and think to myself, “there really needs to be an article published about this”. I am thinking of a slight change in direction to focus a series on self-assurance. There seems to be a growing expectation and ASQA are literally providing no guidance. We need to be collaborating on self-assurnce to develop some common approaches that we can all benifit from. It is something that I have given a lot of thought about, so I am happy to contribute my ideas in a future article series on self-assurance. Let me know if you think this would be helpful or if you have any other suggestions. Your feedback is always appreciated. The best way to contact me is via email.

 

Good training,

Joe Newbery

Published: 19th April 2024

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