AQTF Essential Conditions and Standards for Continuing Registration AUDIT REPORT

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1 AUDIT REPORT RTO DETAILS RTO Name Address Registration Contact Kim Louise Lucas trading as Casey College of Beauty Therapy Now Casey College of Beauty Therapy Pty Ltd NTIS Number Unit 6, 1441 South Gippsland Highway, Cranbourne Kim Lucas Website therapy.com Phone Number Course Code Course Name WRB50105 Diploma of Beauty Therapy WRB40105 Certificate IV in Beauty Therapy Student Numbers WRB30104 Certificate III in Beauty Services 9 18 WRB30204 Certificate III in Nail Technology 10 6 WRH20109 Certificate II in Hair Dressing 0 0 WRH30109 Certificate III in Hair Dressing 0 0 AUDIT TEAM Lead Auditor Jacqui Hodge Auditor/s Technical Advisor/s Observer/s REGISTERING BODY DETAILS Kellie Hughes (observer note taker) Contact Person Katherine Papastathopoulos Phone Number vet.audit@edumail.vic.gov.au Version AQTF 1 July 2010 Page 1 of 15

2 AUDIT REPORT AUDIT DETAILS Type of Audit Conditions audited Post-initial Standards audited 1.1, 1.2, 1.3, 1.4, , 3, 4, 6, 7, 8, 9. (Conditions 2 & 5 are not required to be audited, see page 3 below) Audit Date/s 20 July and 29 July 2011 Other audit notes 2.1, 2.2, 2.3, 2.4, 2.5, 2.6, , 3.2, 3.3, 3.4 The RTO s details provided by the VRQA showed the RTO was known as Kim Louise Lucas trading as Casey College of Beauty Therapy; however the RTO provided evidence at audit that it has established a company structure. The name is Casey College of Beauty Therapy Pty Ltd. The RTO has advised it has notified the VRQA of this change. ACCOMPANYING REPORTS Yes No VRQA Guidelines Audit Report VRQA Guidelines Re-registration Checklist FOCUS OF AUDIT QUALIFICATION/UNIT OF COMPETENCE/ACCREDITED COURSE NTIS Code Qualification/Unit of Competence/Accredited Course (as per NTIS) Delivery Site WRB30204 Certificate III in Nail Technology A Sladen Street, Cranbourne. 2. Floor 1, 144 Main Street Pakenham. 3. Unit South Gippsland Highway, Cranbourne. WRB50105 Diploma of Beauty Therapy As above WRH30109 Certificate III in Hairdressing Yes Not being delivered INTERVIEWEE/S: Staff name and position; employer name and position; students by program (do not list by name) Kim Lucas Lauren Sullivan Paige Pilois Kristy Byrnes Elizabeth Clapp Hary May CEO/Director Training Manager Student Student Trainer Trainer No Version AQTF 1 July 2010 Page 2 of 15

3 AUDIT REPORT AUDIT SUMMARY 1 Governance Conditions of Registration Compliant Noncompliant 1.1 CEO must ensure the RTO complies with relevant conditions, standards and guidelines 1.2 Fit & Proper Persons Tests 1.3 Input of Trainers and Assessors in senior management decision making Not audited 2 Interactions with the Registering Body 3 Compliance with Legislation 4 Insurance 5 Financial Management 6 Certification & Issuing of Qualifications & Statements of Attainment 7 Recognition of Qualifications Issued by other RTOs 8 Accuracy and Integrity of Marketing 9 Transition to Training Packages/Expiry of Accredited Courses Version AQTF 1 July 2010 Page 3 of 15

4 AUDIT REPORT Summary of non-compliances Conditions of Registration Condition 1 Not compliant: Fit and proper test not sighted for CEO. RTO advised this application is pending. See opportunity for improvement (below). Condition 2 Not audited Condition 3 Not compliant: There are no systems in place by which the RTO reviews and updates information provided to staff and students regarding the impact of legislation on their participation in training and assessment. Condition 4 Compliant Condition 5 Not audited Condition 6 Compliant Condition 7 Compliant: The RTO has policies and procedures in place to recognise qualifications issued by other RTOs. This is communicated to its students and its staff. Condition 8 Compliant: Sampled marketing materials, including flyers for the two qualifications being audited, as well as the RTO s website, which showed that its marketing is ethical, accurate and consistent with its scope of registration. The NRT logo is being used appropriately. Condition 9 Compliant: See opportunity for improvement (below). Recommendations Condition 1: RTO must provide the CEO s fit and proper test. Condition 3: The RTO must establish a suitable system for monitoring and advising its stakeholders about the legislation that impacts their participation in training and assessment. Strengths NA Opportunities for Improvement Condition 1: While the CEO takes an active role in monitoring the RTO s compliance with AQTF requirements, the Training Manager noted that she has not completed a full internal audit against the standards since she began in early In order to ensure compliance, the CEO must ensure that the Training Manager completes regular reviews and develops an action plan for addressing any non-compliances identified. Non-compliances should be reported to the CEO. At present the process is not systematic. Condition 6: The RTO is advised to establish a printing process for their qualifications (testamurs) and/or statements of attainments that would reduce fraud such as a seal/corporate identifier or unique watermark. The RTO is also advised to review the requirements of the AQF 2011 Handbook and start providing students with a record of results with their qualifications. Condition 9: It is highly recommended the RTO reviews its transition policy and procedure so it is clear how it informs itself of changes and that the process takes into account the needs of students during the transition process. Version AQTF 1 July 2010 Page 4 of 15

5 AUDIT REPORT Standard 1: The RTO provides quality training and assessment across all of its operations Audit conclusion Result Element 1.1 Compliant Element 1.2 Not compliant The RTO did not show regular industry consultation for all qualifications on scope, nor did it demonstrate that effective industry consultation had been used in the development or review of its training and assessment strategies. The audit of the training and assessment strategies and documentation showed that they did not provide a clear road map for delivery that could be used by stakeholders. The strategies were generic and did not accurately reflect the following components: 1. The training process. 2. Industry consultation process. 3. The assessment process, including RPL. 4. The validation process. 5. No references were made to continuous improvement processes. It is noted that the unit selection for each qualification was compliant with training package requirements. Rectifications: The RTO needs to provide updated training and assessment strategies for all courses on scope that meet requirements. The RTO must ensure the CEO has signed and approved each strategy. The following elements need to be included in the training and assessment strategy: accurate description of the training and delivery program accurate description of the assessment process and tools used for each unit the process for industry consultation Compliant Non-compliant Not audited Version AQTF 1 July 2010 Page 5 of 15

6 assessment validation processes continuous improvement details about how the strategy meets clients needs how RPL will be provided to participants. Element 1.3 Not compliant The RTO has recently started using a new training and assessment resource package for the delivery of most units in WRB30204 Certificate III in Nail Technology and WRB50105 Diploma of Beauty Therapy. However, it did not use a quality control process to ensure that these resources match with its own training and assessment strategies, assessment recording tools or the unit of competency requirements. In some instances the RTO provided evidence that it is using additional assessments that were not included in the strategies, its documentation or the assessment recording sheets. Resources where not being deployed in a consistent manner. Both staff and students reported that they felt the resources were an improvement to the previous resources used by the RTO. A review of the RTO s training rooms and equipment showed that they meet training package requirements. WRH30109 Certificate III in Hairdressing The RTO did not provide resources for this qualification, as it is not currently delivering the qualification. The RTO was advised that it must keep up to date all resources required for delivery of all qualifications on scope, including training and assessment strategies, delivery materials and facilities, as well as suitable staff. The RTO advised it would remove this course from it scope of registration. Rectification: The RTO must develop a plan to ensure it reviews the training package requirements for each unit in each qualification to ensure the resources being used meet the unit s requirements before the learning and assessment resources are used. It must ensure resources are being used consistently by all trainers. It must ensure its training and assessment documentation (including its assessment recording tools and training and assessment strategy) align with the resources being used. Version AQTF 1 July 2010 Page 6 of 15

7 Element 1.4 Not compliant The following non-compliances were noted: 1. The RTO does not have adequate processes in place to ensure that trainers and assessors have established their vocational competency before being engaged to deliver training and assessment. Only one trainer s file (Elizabeth Clapp) showed sufficient evidence of vocational competency. (It is noted she did not have the required skills matrix.) 2. No trainers had a signed skills matrix. 3. One trainer (Megan Pitt) did not have a completed training and assessment qualification and there was no evidence of any supervision of her training and/or assessment. 4. One trainer (Amy O Loughlin) had very limited records in her file. This showed the RTO does not have a thorough process for ensuring all staff meet requirements before being approved to deliver a qualification. 5. While each trainer and assessor had a personal learning and development plan for 2011, there are insufficient records of recent professional development being undertaken that will meet the requirements of this element. Rectifications: 1. The RTO must establish a staff recruitment process that ensures only trainers for whom vocational competency and other requirements have been established are engaged to deliver training and assessment. 2. A skills matrix for each trainer must be completed, signed and dated and then approved by the RTO Manager. Each skills matrix must provide sufficient detail that will establish the vocational competency and industry skills for each unit the trainer is approved to train and assess. 3. Each staff member must show sufficient current records of professional development that they have undertaken. These must demonstrate that they undertake professional development in vocational education and training (VET) knowledge, industry currency, and trainer/assessor competence. The RTO must establish a process that will ensure its trainer and assessors are undertaking and verifying their professional development. 4. The RTO must show that, for any staff member without a Certificate IV in TAA or TAE, there is a supervision plan in place that will meet the requirements of the element (for example, Megan Pitt). Version AQTF 1 July 2010 Page 7 of 15

8 Element 1.5 Not compliant RPL: The RTO presented a candidate RPL kit. However, the kit needs to provide more information to the learner about each unit s requirements so that learners are assisted in providing sufficient RPL evidence. The RTO did not present any RPL tools that would support the assessor in conducting the RPL process or making the RPL decision. There is no tool that will assist the assessor in ensuring all unit of competency requirements are met during the assessment process. Validation: The RTO did not present sufficient validation evidence that would ensure the following requirements are met: That validation is planned and systematic. The RTO did not provide a schedule for this activity that would ensure all units would be covered over a period of time. That validation and/or moderation is undertaken with parties external to the operation of the RTO as required by VRQA guidelines. Work placement and clinic hours: It is not clear in advice given to the auditor if workplace and clinic hours are the same (i.e. equivalent student can do either) or if both activities are to be completed. Conflicting statements were made about this by the RTO staff. This is not made clear in information provided to students. Units audited WRBBS509A Plan the spa program A review of the assessments provided at audit against the unit of competency requirements showed the following non-compliances: 1. Overview of assessment requirements are not being met: A person who demonstrates competency in this standard must be able to identify the history, development and principles of spa treatments and demonstrate knowledge of the theory of hydrotherapy, Thalassotherapy, Balneo therapy and Kneipp therapy. Version AQTF 1 July 2010 Page 8 of 15

9 2. Critical aspects of assessment are not being met, such as: knowledge of the theory of hydrotherapy, Thalassotherapy, Balneo therapy and Kneipp therapy knowledge and consistent application of safe work practices recognising and managing contraindications maximising the use of available staff and equipment. 3. Unit requirements not assessed: pre- and post-treatment advice privacy contraindications. 4. Auditor identified that some required skills are not assessed, such as: problem-solving skills to sequence sap treatments that meet clients and make efficient use of staff and equipment literacy skills prepare individual client treatment plans numeracy skills. 5. Some elements of the required knowledge are not assessed, including: detailed knowledge of features and benefits of wet and dry room therapies in the workplace range workplace policies and procedures in regard to selecting and sequencing spa treatments factors likely to affect the suitability of each sap treatment to client needs and the effects and benefits of each step in the spa treatment sequence basic nutrition and relationship between nutrition and healthy skin, particularly foods which may have an effect on the skin; Version AQTF 1 July 2010 Page 9 of 15

10 In addition some assessment documentation is not consistent, such as: Student Activity Summary: this document does not make it made clear to students or trainers whether the learning activities are assessable. Trainer Assessment Checklist: this document needs more detail as it does not detail the assessment criteria provided to students. WRB5015 Diploma of Beauty Therapy The following two units were audited: WRB201B Provide manicure and pedicare services (this unit is co-delivered with WRBCS204A Apply knowledge of nail science to nail services). The following non-compliances were observed: 1. There is inconsistency in the assessment documentation for example, the Session plan shows four assessments whereas the Trainer assessment checklist shows three. 2. There are additional assessment tasks that are not reflected in the student assessment information sheet, the trainer s guide or assessment record sheet, and the assessment summary tool for example, written assessment 1 hour exam. 3. The following required skills and knowledge have not been addressed: technical skills to: apply massage movement, including effleurage, petrissage and tapotement; apply infection control procedures infection control procedures and universal precautions workplace policies and procedures in regard to the performance of manicure and pedicare services effects of changes created by complementary nail shapes and colour polish/varnish application care and cleaning requirements for manicure and pedicare implements. 4. The following critical aspects have not been addressed: interpreting and applying manufacturer instructions and safety data sheets for use of products, tools and equipment applying range of massage movements, including effleurage, petrissage and tapotement. Version AQTF 1 July 2010 Page 10 of 15

11 5. The assessment tools need to be improved, such as: the log book needs a process by which it can be authenticated Student Activity Summary need to make it clear to students or trainers whether the learning activities (1 9) are assessable a marking guide needs to be provided for all assessments. BSBSBM301A Research business opportunities A review of the assessments provided at audit against the unit of competency requirements showed the following non-compliances: 1. The assessments were not valid or reliable, as the following requirements were not assessed: a. Underpinning skills: i. Ability to relate to people from a range of social, cultural and ethnic backgrounds and physical and mental abilities. b. Underpinning knowledge: i. National, State/Territory and Local Government legislative requirements affecting business operation, especially in regard to Occupational Health and Safety and environmental issues, EEO, industrial relations and anti-discrimination. ii. iii. Legislation and regulations relevant to the business operation. Methods of identifying relevant specialist services to complement the business opportunity. 2. The assessment documentation was not clear and therefore does not meet the rules of assessment in regards to fairness or reliability. For example: a. Student Activity Summary shows eight activities. b. Written Assessment Activity shows four activities, which does not match the Student Activity Summary above. c. Trainer Assessment Checklist showed one assessment task, which is called A: Research business opportunities. The checklist does not provide sufficient information to the trainer as it is a repeat of the unit of competency information. A trainers marking guide was not provided for this task. 3. The student workbook has a range of learning activities it is not clear if these are part of the assessment evidence. Version AQTF 1 July 2010 Page 11 of 15

12 WRH30109 Certificate III in Hairdressing The RTO did not provide resources for this qualification as it is not delivering the qualification. The RTO was advised that it must keep all resources required for delivery up to date, including training and assessment strategies, delivery materials and facilities, as well as suitable staff for all qualifications on scope. Rectifications 1. The RTO needs to review its RPL assessment protocols to ensure that advice is provided to assessors that will assist them in ensuring all unit of competency requirements are met during the assessment process. 2. The RTO needs to review its RPL assessment kit to ensure it provides more information to the learner about each unit s requirements so that learners are assisted during the process of preparing evidence of competency. 3. The RTO needs to provide validation evidence that shows validation is planned and systematic and that validation and/or moderation is undertaken with parties external to the operation of the RTO as required by VRQA guidelines. 4. The RTO needs to provide evidence that it has reviewed its assessment materials to ensure that they meet the unit of competency requirements and that assessment is conducted within the rules and principles of assessment. 5. The RTO needs to provide evidence that is has made the clear to all staff and students the assessment requirements for workplace and clinic hours. Strengths NA Opportunities for Improvement Element 1.1 The RTO is encouraged to review its continuous improvement process, which is largely reactive and based on responding to individual issues raised. They should develop a systematic process for conducting internal reviews of all data and systems. The RTO does not have a process for ensuring all continuous improvement items raised have been completed. Version AQTF 1 July 2010 Page 12 of 15

13 Standard 2: The RTO adheres to principles of access and equity and maximises outcomes for its clients Audit conclusion Result Element 2.1 Compliant Element 2.2 Compliant Element 2.3 Not compliant Written agreements provided to students do not provide clear advice in regard fees, refunds and deferrals. The RTO does not make it clear in its payment agreement and information that it is applying option 3 from Condition 5 in regard to student fees. It is unclear that students who are self-funded are not expected to pay the full fee in advance. The deferral policy does not make it clear to students what obligations they would have (in the event of an early deferral) in regards to payments for student kits that are provided as part of the course fees. The deferral policy is signed by all students on enrolment. It makes additional statements about student s fees and payments. All fee information and student agreements about fees should be in the RTO fees and refunds policy. The student induction checklist asks to student to sign that they have read a duty statement this is not relevant to the student as it appears to be a reference to staff duty statements. Rectifications: The RTO needs to update its fees and refunds policy, its deferral policy and its student induction checklist to ensure the information provided to student is clear and accurate. Element 2.4 Not compliant Students are expected to complete a work placement. However, the host workplace agreement does not provide sufficient information to meet the requirements of this element. For example: the process by which workplace personnel will be informed of their training and assessment roles and responsibilities how the RTO will monitor the contribution of workplace personnel in supporting each learner s training and assessment Compliant Non-compliant Not audited Version AQTF 1 July 2010 Page 13 of 15

14 how the RTO will monitor the learners progress how the RTO will use information received from workplace personnel (who assist with student placements) to make improvements. Rectification: The RTO needs to redevelop its work placement booklet and agreements so the requirements of this unit are met (as above). Element 2.5 Compliant Element 2.6 Not compliant Students do not have sufficient information regarding how to access their records. Rectifications: The RTO needs to provide evidence that it provides information to students on how to access their records. Element 2.7 Not compliant The RTO provided two versions of the complaint and appeals policy. It was not clear which was the current version. Neither version provided a timeframe for resolving informal complaints. The formal processes outlined do not provide any timelines for dealing with a complaint. It provided no information on an external appeals or complaints process and complainants are not advised of their rights to have someone assist them during any complaints meetings. Students rights during the complaints process are not stated. Complaints and appeals data and/or outcomes are not linked to continuous improvement activities of the RTO. Rectification: The RTO needs to provide a reviewed complaint and appeals policy that addresses the issues raised above. Strengths NA Opportunities for Improvement NA Version AQTF 1 July 2010 Page 14 of 15

15 Standard 3: Management systems are responsive to the needs of clients, staff and stakeholders, and the environment in which the RTO operates Audit conclusion Result Standard 3 Compliant Element 3.1 Compliant Element 3.2 Compliant Element 3.3 Compliant The RTO advised there are no plans for any partnerships. Element 3.4 Compliant Non-compliant Not audited Strengths NA Opportunities for Improvement Element 3.4 The RTO is encouraged to develop a version control process for printed documents, such that staff and students can be sure printed documents are the current approved version. Two different versions of the complaints and appeals policies were presented. Version AQTF 1 July 2010 Page 15 of 15