VET Quality Framework audit report of Enrich Training

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1 VET Quality Framework audit report of Enrich Training Prepared for APAC Renewal registration as a national VET regulator (NVR) registered training organisation (RTO) Legal name of RTO Enrich Training Date/s of audit 6 January 2013 RCA-P-AUR-REP001 Version 1.1 (30 June 2011) Uncontrolled when printed Page 1 of 22

2 APPLICANT DETAILS Applicant legal name Enrich Training Pty Ltd as trustee for the Enrich Training Unit Trust RTO ID number Registered business trading name Enrich Training Unit Trust ABN Address 14 Goulburn Street GORDON PARK QLD 4031 Postcode Phone (07) Fax (07) Website Registration contact Name Ms Helen Batterham Position Director AUDIT TEAM Lead auditor Isobel Kidd AUDITOR CONTACT DETAILS Phone AUDIT DETAILS Scope of audit Standards for NVR RTOs Australian Qualifications Framework (AQF) Data Provision Requirements Fit and Proper Person Requirements Financial Viability Risk Assessment Requirements Date/s of site visit/s Desk audit, December-January 2013 Applicant currently operates as an RTO but is seeking new registration due to a change in its ownership or management Site/s visited NA Essential Standards audited All ORGANISATION Enrich Training Pty Ltd is a small RTO operating in Brisbane, Enrich Training, national code The RTO has approximately 120 students currently enrolled in the TAE The RTO currently has 10 qualifications on its scope of registration. Training is based on 50% face to face and workplace based. The RTO currently has no online training and uses a combination of purchased commercial (e.g. Aspire) and customised resources. The RTO is a current provider on the APL. FOCUS OF AUDIT Code Qualification / Accredited course name Mode(s) of delivery &/or assessment TAE40110 Certificate IV in Training and Assessment Face to face/ online BSB51107 Diploma of Management Face to face/ online BSB40807 Certificate IV in Frontline Management Face to face/ online Current version: 2012/12/17 Page 2 of 22

3 SUMMARY OF AUDIT OUTCOME This audit was conducted under the National Vocational Education and Training Regulator Act 2011 (the Act) to assess compliance with requirements of the VET Quality Framework as identified under the Scope of Audit section above. AUDIT OUTCOME Audit status as at 6 January 2013 The organisation has NOT demonstrated compliance with all compliance requirements reviewed for the audit. The extent of non-compliance is considered low when considering the potential for adverse impact on the quality of training and assessment outcomes for students. The audit report describes evidence of non-compliance identified. Each issue referenced must be rectified by the organisation with evidence provided to RQA Product Risk Institute Auditor s Name Isobel Kidd Signature Date of Report 06 January 2013 Current version: 2012/12/17 Page 3 of 22

4 Audit conclusion The RTO has a quality management system in place for the management of the RTO. The following compliance areas were not assessed: - No records were examined in this audit review - APL compliance was not included in this audit review - Financial viability was not included in this audit review (SNR 22.1) Overall the RTO appears to have good training and assessment practices in place and is committed to the provision of quality training and assessment. The training and assessment resources developed by the RTO are of a high quality. The Aspire resources are generic and although they adequately meet the requirements of the training package require additional customisation. A number of continuous improvement suggestions are contained in this report against each element of the SNR as relevant. Overall there were four (4) areas identified as non compliances. It is the auditor s recommendation that the additional evidence to be submitted to RQA Product Risk Institute. It is very likely that the RTO has evidence of compliance in the areas identified as non-compliances and that the evidence was not submitted for this audit review. Summary of Findings of non-compliance: Additional Evidence Required SNR 15.1/ 16.2 The RTO must provide information providing evidence with data provision requirements as per the General Direction Quality Indicators and the Competency Completion Online System for the reporting of competency completion data. See and General Direction for Quality Indicators (24/04/2012). The RTO must provide evidence of the schedule for the completion of the continuous improvement activities including; - Trainer/ assessor meetings - Completion of ASQA data requirements (see audit report SNR 16.2) - How and when trainer/ student/ employer feedback is analysed and reviewed SNR 16.3 The Student Information Booklet should be updated to include ASQA references, including reference to the ASQA complaints process. SNR 23.4 The RTO must provide information providing evidence with data provision requirements as per ASQA requirements for Competency Completion Online System for the reporting of competency completion data. See The RTO must provide information about how it ensures compliance with AVETMISS data collection requirements. SNR 24.2 The RTO must provide evidence it has changed the use of the NRT logo on its web site. Current version: 2012/12/17 Page 4 of 22

5 Insufficient evidence provided for the following standards so no conclusion could be made: It is the auditor s recommendation that the additional evidence to be submitted to RQA Product Risk Institute. SNR 15.2 Training and Assessment Strategies No strategies provided, no evidence of industry consultation SNR 15.4 and 15.5 Trainers/ Assessors No trainer and assessor qualifications were reviewed SNR 18.1 Compliance of the RTO The RTO has a comprehensive quality management system in place for the management of the RTO. However it is unknown how the RTO manages data reporting requirements (see SNR 23.4). SNR 23.4 Data reporting requirements No evidence provided of how the RTO manages data reporting requirements SNR 23.5 National unique student identifier No evidence provided of how the RTO manages requirements for the provision of a national student identifier. SNR 25.1 Transition to Training Packages/expiry of VET accredited course No evidence provided of how the RTO manages the transition of training packages. Current version: 2012/12/17 Page 5 of 22

6 Enrich Training Pty Ltd AUDIT REPORT SNR 15 The NVR registered training organisation provides quality training and assessment across all of its operations, as follows: 15.1 The NVR registered training organisation collects, analyses, and acts on relevant data for continuous improvement of training and assessment. The RTO has policies and procedures in place for the monitoring, evaluation and continuous improvement of training and assessment activities. These policies are summarised on the Policies and Procedures Overview document and communicated to students in the Student Information Booklet. Relevant policies and procedures include; - Policy 8.0 Continuous improvement policy - Procedure 8.0 Continuous Improvement Procedure - Policy 7.0 Quality Management - Procedure 7.2 Internal Audit - Procedure 7.3 Risk Management - Procedure 7.4 System Improvement - Procedure 5.8 Course Review - Form Training Evaluation Form - Form Employer Feedback Form - Form 5.11 Unit evaluation form - Form 5.10 Feedback analysis form - Form 6.1 Complaints and Appeals Form - Form 7.2 Internal audit report - Form System Improvement The results of the review and monitoring of training activities are reviewed and recorded on the continuous improvement register. There is no reference in the policies or procedures to the data collection requirements of ASQA, including the collection of Quality Indicator Reporting and competency completion data reporting requirements. Continuous Improvement Suggestion The RTO has a lot of forms in place which could be rationalised and possibly placed online. For example; - Form 6.1 Complaints and Appeals Forms and Form Participant Access Request could be documented online/ based - Marketing client consent this could be included on the student enrolment form - Form Document Control Register this is a redundant register. File storage and file naming/ document control systems indicate currency of system documents Current version: 2012/12/17 Page 6 of 22

7 Findings of non-compliance: Additional Evidence Required The RTO must provide information providing evidence with data provision requirements as per the General Direction Quality Indicators and the Competency Completion Online System for the reporting of competency completion data. See and General Direction for Quality Indicators (24/04/2012). The RTO must provide evidence of the schedule for the completion of the continuous improvement activities including; - Trainer/ assessor meetings - Completion of ASQA data requirements (see audit report SNR 16.2) - How and when trainer/ student/ employer feedback is analysed and reviewed 15.2 Strategies for training and assessment meet the requirements of the relevant Training Package or VET accredited course and have been developed through effective consultation with industry. No training and assessment strategies were provided for the purposes of the audit. No evidence provided of industry consultation in the development of the training and assessment strategies. Insufficient evidence Findings of non-compliance: 15.3 Staff, facilities, equipment and training and assessment materials used by the NVR registered training organisation are consistent with the requirements of the Training Package or VET accredited course and the NVR registered training organisation s own training and assessment strategies and are developed through effective consultation with industry. Current version: 2012/12/17 Page 7 of 22

8 The RTO uses a combination of in-house and commercially developed materials. The training and assessment materials for the TAE40110 have been developed in-house. TAE40110 has the following resources in place: - Learning resources - Study and assessment guide booklet - Assessment tools - Assessment mapping guide - Assessment instruction booklet - Assessor guide and markers guide - Competency assessment sheet/ records Diploma of Management (BSB51107) and Certificate IV in Frontline Management (BSB40807) are using Aspire training and assessment materials. These consist of: - Learning materials (Aspire) - Delivery slides (Aspire) - Delivery plans (Aspire) an Aspire based Training and Assessment Strategy - Assessment tool (Aspire) - Assessment record cover sheet (Enrich) - Trainer and assessor guide (Aspire) The RTO has policies and procedures in place to ensure compliance with training package requirements in relation to training and assessment development. None of the documents however refer to industry consultation and liaison in the development of training and assessment strategies, resources and tools. The procedure for assessment development (Procedure 5.2) refers to Ensure assessment activities cover all aspects of competency, are appropriate to the target group and, focus on the standard of workplace performance but does not specify how this is determined. Relevant procedures include: - Procedure 5.1 Course Development - Procedure 5.3 Assessment Development - Procedure 5.5 Course Delivery - Student Information Booklet (page 4 RPL and credit transfer) The RTO has policies and procedures in place for RPL and credit transfer (Procedure 5.4 RPL/Credit Transfer). Insufficient evidence (SNR 15.2) 15.4 Training and assessment is delivered by trainers and assessors who: (a) have the necessary training and assessment competencies as determined by the National Skills Standards Council or its successors; and (b) have the relevant vocational competencies at least to the level being delivered or assessed; and (c) can demonstrate current industry skills directly relevant to the training/assessment being undertaken; and (d) continue to develop their vocational education and training (VET) knowledge and skills as well as their industry currency and trainer/assessor competence. Current version: 2012/12/17 Page 8 of 22

9 No evidence was provided of trainers and assessors who will deliver the training and assessment services. The RTO provided evidence that it has in place: - Procedure Staff Recruitment and Induction - Procedure Performance Review and Development The RTO did not provide evidence that it has in place, although these were not requested during the audit: - Trainer Handbook - Trainer/ assessor matrix - Regular meetings with trainers and assessors - Contracts with trainers and assessors TBA Evidence guidance: Sampling: For each qualification, auditor should review all trainer/assessors credentials, considering: Persons from partnering organisations working on behalf of the RTO Persons who operate from a range of RTO sites (e.g. Enrich workplace assessors) Persons who deliver units with particular technical requirements Persons who work under supervision of others (review both persons credentials). Trainer credentials: For each trainer/assessor reviewed, evidence is required to confirm: training and assessment competencies: TAA40110; or equivalence to TAE40110; or under direct supervision vocational competency relevant to the qualification/accredited course to be delivered how their industry skills/experience relate to each unit to be delivered how they will develop their professional skills as a trainer/assessor how their various credentials have been verified for authenticity how the applicant has verified the trainer/assessor s commitment to deliver training and/assessment services. Evidence gathered: [Copy and paste section below for each trainer/assessor reviewed] Trainer name Nominated to deliver quals/courses/units EVIDENCE GATHERED Current and relevant evidence only SUFFICIENT Trainer/assessor competencies Vocational competence Industry certification & licences Vocational competence Industry experience & exposure Relationship between skills/experience and units Current version: 2012/12/17 Page 9 of 22

10 Strategies to develop of VET knowledge & skills Strategies to develop industry currency Strategies to develop trainer/assessor competence Authenticity of trainer/assessor s credentials is verified Commitment of trainer/assessor to deliver for applicant is verified Insufficient evidence 15.5 Assessment including Recognition of Prior Learning (RPL): (a) meets the requirements of the relevant Training Package or VET accredited course; and (b) is conducted in accordance with the principles of assessment and the rules of evidence; and (c) meets workplace and, where relevant, regulatory requirements; and (d) is systematically validated. Evidence: [Copy and paste section below for each qualification reviewed] The RTO uses a combination of in-house and commercially developed materials. The assessment materials for the TAE40110 have been developed in-house. TAE40110 has the following resources in place: - Study and assessment guide booklet - Assessment tools - Assessment mapping guide - Assessment instruction booklet - Assessor guide and markers guide - Competency assessment sheet/ records The RTO uses a clustered approach to the assessment of the units. This is set out in the TAE40110 Assessment Mapping Guide. The resources developed by the RTO are compliant with training package requirements. Diploma of Management (BSB51107) and Certificate IV in Frontline Management (BSB40807) are using Aspire training and assessment materials. These consist of: - Delivery plans (Aspire) an Aspire based Training and Assessment Strategy - Assessment tool (Aspire) - Assessment record cover sheet (Enrich) - Trainer and assessor guide (Aspire) Assessment materials from one sample unit of competency were reviewed for the purposes of this audit for the Diploma of Management (BSB51107) and Certificate IV in Frontline Management (BSB40807); BSBWOR501A Manage personal work priorities and professional development and BSBMGT401A Show leadership in the workplace. The RTO has not modified the assessment materials but has customised an assessment checklist which clearly outlines for students the assessment requirements for each unit of competency. Continuous Improvement Suggestion The RTO should customise the Aspire assessment tools and include the same information for students as it does for TAE Current version: 2012/12/17 Page 10 of 22

11 Qualification Unit 1 Diploma of Management (BSB51107) BSBWOR501A Manage personal work priorities and professional development Assessment instruments Aspire assessment tools Supporting tools & guides Assessment Checklist, Aspire LR Assessment records, Aspire LR Trainer and Assessor s Guide Unit 2 Assessment instruments Validation & Moderation SUFFICIENT Evidence of validation of each of these two units of competency were provided and were completed by Helen Batterham (20/12/2012). Assessment processes and evidence gathering mechanisms: Satisfy assessment guidelines of training package or accredited course (incl. pre- or corequisites) Unit 1 Unit 2 evidence Qualification BSBMGT401A Show leadership in the workplace Aspire assessment tools Supporting tools & guides Assessment Checklist, Aspire LR Assessment records, Aspire LR Trainer and Assessor s Guide Meet all applicable regulatory requirements (e.g. mandated assessments) Ensure competent students possess workplace-relevant skills and knowledge Are systematically validated and moderated Address all elements of competency, essential knowledge and skills and critical aspects of Cover the range statement in a relevant assessment context Cover all dimensions of competency as appropriate for the AQF level Inform assessors and students about competent performance requirements Enable assessment of existing competence and provision of assessment feedback Certificate IV in Training and Assessment TAE40110 Unit 1 Assessment instruments TAEASS301B Contribute to Assessment Student Assessment Booklet Supporting tools & guides TAE40110 Marking guide TAE40110 Assessment Mapping guide Competency record Enrich study and assessment guide booklet Unit 2 TAEDES402A Use Training Packages and accredited courses to meet client needs Assessment instruments Student Assessment Booklet Supporting tools & guides TAE40110 Marking guide TAE40110 Assessment Mapping guide Competency record Enrich study and assessment guide booklet Validation & Moderation Evidence of validation of each of these two units of competency were provided and were completed by Helen Batterham (18/12/2012). Current version: 2012/12/17 Page 11 of 22

12 SUFFICIENT Assessment processes and evidence gathering mechanisms: Satisfy assessment guidelines of training package or accredited course (incl. pre- or corequisites) Unit 1 Unit 2 evidence Meet all applicable regulatory requirements (e.g. mandated assessments) Ensure competent students possess workplace-relevant skills and knowledge Are systematically validated and moderated Address all elements of competency, essential knowledge and skills and critical aspects of Cover the range statement in a relevant assessment context Cover all dimensions of competency as appropriate for the AQF level Inform assessors and students about competent performance requirements Enable assessment of existing competence and provision of assessment feedback SNR 16 The NVR registered training organisation adheres to principles of access and equity and maximises outcome for its clients, as follows 16.1 The NVR registered training organisation establishes the needs of clients, and delivers services to meet these needs. The RTO has policies and procedures in place for the planning and delivery of training and assessment services. These are communicated to clients and monitored. Students apply to the RTO for study based on individual requirements in their course of choice. Relevant policies and procedures that support compliance with SNR 16 include; - Policy 2.0 Student Enrolment and Participation - Policy 5.0 Course Planning, Delivery And Completion - Student enrolment form - Course outlines - Marketing materials paper based and on the Enrich web site - Student handbook and learner guides - Feedback processes and forms for trainers employers and students - Feedback analysis form - Procedure 2.1 Student Enrolment - Procedure 2.2 Student Attendance - Procedure 2.3 Student Record Management 16.2 The NVR registered training organisation continuously improves client services by collecting, analysing and acting on relevant data. See Audit Report SNR 15.1 Current version: 2012/12/17 Page 12 of 22

13 Findings of non-compliance See Audit Report SNR Before clients enrol or enter into an agreement, the NVR registered training organisation informs them about the training, assessment and support services to be provided, and about their rights and obligations. The RTO has a range of policies and procedures in place to provide students with sufficient information prior to enrolment. The Enrich Student Information Booklet is on the website (Version 5 14/2/11). The student enrolment form contains a summary of Policy Participant Fees Charges and Refunds for students on enrolment. Supporting processes, policies, procedures and forms which support compliance with SNR 16.3 include: Form Marketing Client Consent (privacy). The Student Information Booklet does not contain any information about ASQA as it was written prior to the inclusion of QLD RTO s in July There is no reference to the complaints mechanisms through ASQA. Finding of Non-Compliance: Additional Evidence Required The Student Information Booklet should be updated to include ASQA references, including reference to the ASQA complaints process Employers and other parties who contribute to each learner s training and assessment are engaged in the development, delivery and monitoring of training and assessment. Current version: 2012/12/17 Page 13 of 22

14 The RTO has policies and procedures in place for the planning and delivery of training and assessment services. These are communicated to employers and clients. Students apply to the RTO for study based on individual requirements in their course of choice and therefore there is no involvement from employer organisations in workplace based supervision, training and assessment, based on the information provided. The unit of competency: BSBWOR501A Manage personal work priorities and professional development, an Aspire publication, indicates involvement with a Supervisor in the assessment. This needs to be clarified by the RTO. Students apply to the RTO for study based on individual requirements in their course of choice. Relevant policies and procedures that support compliance with SNR 16 include; - Policy 2.0 Student Enrolment and Participation - Policy 5.0 Course Planning, Delivery And Completion - Student enrolment form - Course outlines - Marketing materials paper based and on the Enrich web site - Student Information Booklet and learner guides - Feedback processes and forms for trainers employers and students - Feedback analysis form - Procedure 2.1 Student Enrolment - Procedure 2.2 Student Attendance - Procedure 2.3 Student Record Management Continuous Improvement Suggestion The RTO should document communication documentation provided to workplaces and workplace supervisors when relevant. For example in the Diploma of Business (BSB51107), the unit of competency BSBWOR501A Manage personal work priorities and professional development Learners receive training, assessment and support services that meet their individual needs. On enrolment students are requested to identify disabilities, medical conditions, literacy assistance etc. This information is documented by the students on the enrolment forms. The qualifications which the RTO provides are at Certificate IV and Diploma level and candidates are self-selected. Information is provided in the Student Information Booklet (online) and the Study and Assessment Guides about the provision of assistance to students and the processes which the RTO has in place Learners have timely access to current and accurate records of their participation and progress. The RTO has a form in place for students to request access to their student records; Form Participant Access Request. This is documented in the Student Information Booklet on the website (page 6). Student progress is monitored and managed by the RTO; course cover summary competency sheets etc. Current version: 2012/12/17 Page 14 of 22

15 16.7 The NVR registered training organisation provides appropriate mechanisms and services for learners to have complaints and appeals addressed efficiently and effectively. The RTO has a process in place for the management of complaints and appeals and a form for students; Form Complaints and Appeals Form. Continuous Improvement Suggestion The RTO must document student s rights to complain to ASQA on the Student Information Booklet. SNR 17 Management systems are responsive to the needs of clients, staff and stakeholders, and the environment in which the NVR registered training organisation operates, as follows: 17.1 The NVR registered training organisation s management of its operations ensures clients receive the services detailed in their agreement with the NVR registered training organisation. The RTO has a quality management system in place for the management of the RTO. No records were examined in this audit review The NVR registered training organisation uses a systematic and continuous improvement approach to the management of operations. The RTO has a comprehensive quality management system in place for the management of its operations. However much of the documentation dates back to 2006 (e.g. Form Document Control Register) and does not contain references to ASQA or the SNR, Standards for NVR RTOs. The documentation refers to the AQTF. The Standards for National VET Regulator (NVR) Registered Training Organisations 2011 have replaced the former AQTF standards for relevant applicants/rtos. The organisation has good document control mechanisms in place. Continuous Improvement Suggestion The RTO must update documentation with references to the SNR and ASQA requirements. ASQA is referred to as the National VET Regulator in several documents (e.g. Policy Student Enrolment and Participation and Policy Course Planning, Delivery and Completion) and as it is the sole regulator it is relevant to ensure all documentation is up-to-date and clearly communicated to students The NVR registered training organisation monitors training and/or assessment services provided on its behalf to ensure that it complies with all aspects of the VET Quality Framework. Current version: 2012/12/17 Page 15 of 22

16 The RTO has one partnership arrangement in place with Ron Pollak Consulting & Training for the delivery of BSB40607 Certificate IV in Business Sales and BSB40807 Certificate IV in Frontline Management. The organisation has an MOU in place. However this is not dated and contains outdated references to the AQTF 2007 essential standards for RTO s (page 2). The MOU does not document monitoring of student records and marketing activities undertaken by Ron Pollack Consulting & Training and does not contain a schedule for the review of the arrangement or compliance of the partnership organisation. Additional Evidence Required The RTO must update documentation with references to the SNR and ASQA requirements and must include how the arrangement is monitored and reviewed The NVR registered training organisation manages records to ensure their accuracy and integrity. The RTO has a records management system in place which is documented in Procedure Student Records Management. Each course has a course cover sheet and progress sheet to indicate completion of units of competency within qualifications. The RTO did not provide information of the system used to maintain the records system. SNR 18 The NVR registered training organisation has governance arrangements in place as follows: 18.1 The NVR registered training organisation s Chief Executive must ensure that the NVR registered training organisation complies with the VET Quality Framework. This applies to all of the operations within the NVR registered training organisation s scope of registration, as listed on the National Register. The RTO has a comprehensive quality management system in place for the management of the RTO. However it is unknown how the RTO manages data reporting requirements (see SNR 23.4). Insufficient evidence 18.2 The NVR registered training organisation must also explicitly demonstrate how it ensures the decision making of senior management is informed by the experiences of its trainers and assessors. The policies and procedures of the RTO state that trainers are involved in the continuous improvement cycle. However there is insufficient information on the mechanisms and schedules for this to take place; e.g. regular trainer meetings/ meeting minutes/ agendas/ continuous improvement schedule Additional Evidence Required The RTO should provide evidence of how the information is communicated to trainers before/ on employment. E.g. Trainer Handbook The RTO should provide evidence of the mechanisms and schedules for this to take place; e.g. regular trainer meetings/ meeting minutes/ agendas/ continuous improvement schedule Current version: 2012/12/17 Page 16 of 22

17 SNR 19 The NVR registered training organisation has governance arrangements in place as follows: 19.1 The NVR registered training organisation must co-operate with the National VET Regulator: (a) in the conduct of audits and the monitoring of its operations; (b) by providing accurate and timely data relevant to measures of its performance; (c) by providing information about significant changes to its operations; (d) by providing information about significant changes to its ownership; and (e) in the retention, archiving, retrieval and transfer of records consistent with the National VET Regulator's requirements. No evidence provided of internal audit reports. The RTO has a policy for internal auditing as part of the Continuous Improvement policy (Policy 8) which states that will be carried out annually. There is an Internal Audit Report Form (Form 37.2) based on the SNR. SNR 20 Compliance with legislation 20.1 The NVR registered training organisation must comply with relevant Commonwealth, State or Territory legislation and regulatory requirements relevant to its operations and its scope of registration. The RTO has a work health and safety system in place (Policy 11 WHS, Procedure 11.1 WHS, Procedure 7.3 Risk Management). Trainers are required to complete a Hazard Identification Checklist (Form 11.1) and there is an Accident Incident Report Form (Form 11.2) if required. Trainers are required to conduct a hazard identification prior to each training session and report appropriately. The RTO is on the APL and as such is required to comply with the requirements of the QLD Department of Education and Training The NVR registered training organisation must ensure that its staff and clients are fully informed of legislative and regulatory requirements that affect their duties or participation in vocational education and training. The RTO provides information to students and trainers on legislative compliance. Information on WHS and other legislative and regulatory requirements is included in the Student Information Booklet (pages 5-8). The RTO has a work health and safety system in place (Policy 11 WHS, Procedure 11.1 WHS, Procedure 7.3 Risk Management). Additional Evidence Required The RTO should provide evidence of how the information is communicated to trainers before/ on employment. E.g. Trainer Handbook SNR 21 Insurance Current version: 2012/12/17 Page 17 of 22

18 21.1 The NVR registered training organisation must hold public liability insurance throughout its registration period. Not included in audit SNR 22 Financial management 22.1 The NVR registered training organisation must be able to demonstrate to the National VET Regulator, on request, that it is financially viable at all times during the period of its registration. Not included in audit The RTO has a policy on Financial Management (Policy 10). Insufficient evidence 22.2 The NVR registered training organisation must provide the following fee information to each client: (a) the total amount of all fees including course fees, administration fees, materials fees and any other charges; (b) payment terms, including the timing and amount of fees to be paid and any non-refundable deposit/administration fee; (c) the nature of the guarantee given by the NVR registered training organisation to complete the training and/or assessment once the student has commenced study in their chosen qualification or course; (d) the fees and charges for additional services, including such items as issuance of a replacement qualification testamur and the options available to students who are deemed not yet competent on completion of training and assessment; and (e) the organisation s refund policy. The RTO provides clear information to students on fees and terms and conditions of enrolment. The policy and procedure includes information on payment terms, fees, transfer arrangements, cancellation and refund policy etc. The RTO has the following documents to support compliance with SNR 22.2: - Policy Participant Fees Charges and Refunds - Procedure Participant Fees and Refunds - Student information booklet (on web site) - Course application forms 22.3 Where the NVR registered training organisation collects student fees in advance it must ensure it complies with one of the following acceptable options: (a) (Option 1) the NVR registered training organisation is administered by a State, Territory or Commonwealth government agency; (b) (Option 2) the NVR registered training organisation holds current membership of an approved Tuition Assurance Scheme; (c) (Option 3) the NVR registered training organisation may accept payment of no more than $1000 from each individual student prior to the commencement of the course. Following course Current version: 2012/12/17 Page 18 of 22

19 commencement, the NVR registered training organisation may require payment of additional fees in advance from the student but only such that at any given time, the total amount required to be paid which is attributable to tuition or other services yet to be delivered to the student does not exceed $1,500; (d) (Option 4) the NVR registered training organisation holds an unconditional financial guarantee from a bank operating in Australia for no less than the full amount of funds held by the NVR registered training organisation which are prepayments from students (or future students) for tuition to be provided by the NVR registered training organisation to those students; or (e) (Option 5) the NVR registered training organisation has alternative fee protection measures of equal rigour approved by the National VET Regulator. The RTO is on the APL and provides traineeships. The RTO practices option 3 (above). Private courses are charged fees of more than $1000 (e.g. TAE40110). The RTO provides students with payment options of maximum $400 payments. SNR 23 Certification, issuing and recognition of qualifications & statements of attainment 23.1 The NVR registered training organisation must issue to persons whom it has assessed as competent in accordance with the requirements of the Training Package or VET accredited course, a VET qualification or VET statement of attainment (as appropriate) that: (a) meets the Australian Qualifications Framework (AQF) requirements; (b) identifies the NVR registered training organisation by its national provider number from the National Register and (c) includes the NRT logo in accordance with current conditions of use. The RTO has policies and procedures in place to ensure that compliant statements of attainment and qualifications are issued; Procedure Issue of Qualifications and Statement of Attainments. Sample statements of attainment and qualifications were sighted and found to be compliant The NVR registered training organisation must recognise AQF and VET qualifications and VET statements of attainment issued by any other RTO. The RTO provides information to students in the Student Information Booklet which outlines the recognition of VET qualifications and VET statements of attainment issued by other RTO s; page 4) The NVR registered training organisation must retain client records of attainment of units of competency and qualifications for a period of 30 years. Current version: 2012/12/17 Page 19 of 22

20 The RTO has a records management system in place which is documented in Procedure Student Records Management. The RTO did not provide information of the system used to maintain the records system. Students are able to access their student records (Form Participant Access Request) and this is documented in the Student Information Booklet (page 6). Continuous Improvement Suggestion The RTO must update documentation provided to students about the holding of records for 30 years and provision to move student records to ASQA as required The NVR registered training organisation must provide returns of its client records of attainment of units of competency and VET qualifications to the National VET Regulator on a regular basis, as determined by the National VET Regulator. The RTO did not provide any evidence of that it complies with the Competency Completion Online System for the reporting of competency completion data. Although the requirement to have an AVETMISS compliant student management system has been removed from SNR 23, the RTO must still refer to the Data Provision Requirements 2011 (DPR) to meet the obligation to provide the National VET Regulator with AVETMISS compliant data. No evidence of the collection of AVETMISS data was provided. Insufficient evidence Findings of non-compliance: Additional Evidence Required The RTO must provide information providing evidence with data provision requirements as per ASQA requirements for Competency Completion Online System for the reporting of competency completion data. See The RTO must provide information about how it ensures compliance with AVETMISS data collection requirements The NVR registered training organisation must meet the requirements for implementation of a national unique student identifier. No evidence sighted Insufficient evidence Current version: 2012/12/17 Page 20 of 22

21 Findings of non-compliance: The organisation should provide additional evidence of the processes in place to meet the requirements for the implementation of a national unique student identifier. SNR 24 Accuracy and integrity of marketing 24.1 The NVR registered training organisation must ensure its marketing and advertising of AQF and VET qualifications to prospective clients is ethical, accurate and consistent with its scope of registration. The RTO has a policy and procedures in place for ensuring its marketing and advertising of AQF and VET qualifications to prospective clients is ethical, accurate and consistent with its scope of registration.; Procedure Marketing and Advertising The NVR registered training organisation must use the NRT logo only in accordance with its conditions of use. (Note: this refers to the logo conditions in place at the commencement of this instrument.) The RTO has a policy and procedures in place for ensuring compliance with the NRT logo conditions of use; Procedure Issue of Qualifications and Statement of Attainments and Procedure Marketing and Advertising. The RTO is using the NRT logo on its web site with generic references to courses without national codes ( ) and also - NRT logo next to short courses with no reference to accreditation. This is not permissible under the ASQA Guidelines, see ( ). Findings of non-compliance: The RTO must provide evidence it has changed the use of the NRT logo on its web site. SNR 25 Transition to Training Packages/expiry of VET accredited course 25.1 The NVR registered training organisation must manage the transition from superseded Training Packages within 12 months of their publication on the National Register so that it delivers only currently endorsed Training Packages. Current version: 2012/12/17 Page 21 of 22

22 The RTO did not provide any evidence of how it manages the transition and teach out of superseded courses as per the ASQA General Direction on Transition and teach out (14/11/2011). Insufficient evidence Findings of non-compliance - Additional evidence required: The RTO should provide evidence of a policy, procedure and review schedule for its transition and teach out arrangements The NVR registered training organisation must manage the transition from superseded VET accredited courses so that it delivers only currently endorsed Training Packages or currently VET accredited courses. Not applicable Result NA Current version: 2012/12/17 Page 22 of 22

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