Continuing registration as a national VET regulator (NVR) registered training organisation (RTO)

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1 ORGANISATION DETAILS Organisation s legal name Della International College Pty Ltd Trading name/s Della International College Pty Ltd RTO number CRICOS number 02716C AUDIT TEAM Lead auditor Auditors Technical adviser/s Robert East. Christine Williams Jock Blackburn AUDIT DETAILS Application number/s Audit number/s Audit reason 1 Activity type Address of site/s visited Compliance Monitoring Site Visit A Beckett Street. Date/s of audit March 2013 and 25 March 2013 Organisation s contact for audit Amanjot Singh CEO NVR Standards audited SNR Standards 15.2, 15.3, 15.4, 15.5, 16.5 and 17.4 Page 1 of 35

2 BACKGROUND Della International College Pty Ltd is a CRICOS provider operating in the Melbourne CBD and at Sunshine West in Melbourne s western suburbs. It is managed by the CEO with assistance of the Operations and Compliance Manager with training responsibilities being managed by the Business Studies co-ordinator and the Painting and Decorating co-ordinator. Its main focus is on the provision of Business Management at the Diploma and Certificate IV level, the Certificate IV in Information Technology at its city campus with Certificate IV in painting and decorating being delivered from its Sunshine location. Della has been operating since 2006 and its target market is international students with a current capacity of 600 students across the two campuses with 572 CoEs currently studying at both sites. Their courses are generally over 2.5 days per week to provide the international students with the minimum 20 hours per week of training and assessment. Total number of current enrolments in RTO as at audit date: Current number of CoE s is 572 AUDIT SAMPLE Code Qualification / Accredited course name Mode(s) of delivery &/or assessment Current enrolments BSB60407 BSB1107 BSB40507 CPC30611 Advanced Diploma of Management Diploma of Management Certificate IV in Business Administration Certificate III in Painting and Decorating Apprenticeship Distance Face to face Online Mixed Workplace Traineeship Other specify INTERVIEWEES - Staff Name Position Qualification/course Amanjot Singh Amit Asija Kanchan Minakshi CEO. Operations and Compliance Manager Painting and Decorating trainers All Courses All Courses Page 2 of 35

3 AUDIT FINDING ORIGINAL AUDIT FINDING Audit finding as at 25 March 2013 The organisation has not demonstrated compliance with one or more compliance requirements examined for the audit. Level of non-compliance: Critical The level of non-compliance considers the potential for an adverse impact on the quality of training and assessment outcomes for students. If non-compliance has been identified, this audit report describes evidence of the non-compliance. Refer to Notification of non-compliance for information on providing further evidence of compliance. AUDIT FINDING FOLLOWING ANALYSIS OF RECTIFICATION EVIDENCE Audit finding following additional evidence AUDIT FINDING BY REQUIREMENT Standards for NVR Registered Training Organisations 2012 Essential Standards for Continuing Registration Standard Original finding Following rectification SNR 15 Non-compliant Compliant SNR 16 Non-compliant Compliant SNR 17 Non-compliant. Compliant SNR 18 Non-compliant Compliant SNR 19 Not Audited Choose an item. SNR 20 Not Audited. Choose an item. SNR 21 Not Audited Choose an item. SNR 22 Not Audited Choose an item. SNR 23 / AQF Not Audited Choose an item. SNR 24 Not Audited. Choose an item. SNR 25 Not Audited. Choose an item. Page 3 of 35

4 STANDARDS FOR NVR REGISTERED TRAINING ORGANISATIONS ESSENTIAL STANDARDS FOR CONTINUING REGISTRATION 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.. Page 4 of 35

5 15.2 Strategies for training and assessment meet the requirements of the relevant training package or accredited course and have been developed through effective consultation with industry.. BSB40507 Certificate IV in Business Administration, BSB51107 Diploma of Management, BSB60407 Advanced Diploma of Management 1. The Training and assessment strategies for the above qualifications, do not sufficiently identify the required physical resources such as complex software and how specialist resources are upgraded in accordance with current industry practices. 2. The delivery program for each strategy states that international students may commit to 20 hours per week when this is a minimum requirement for international students. BSB40507 Certificate IV in Business Administration: 1. The strategy specifically states that the qualification. is designed for local domestic students. The organisation s representative stated that this program is designed for international students only. The strategies provided did not meet the requirements of the Training Package. BSB40507 Certificate IV in Business Administration, BSB51107 Diploma of Management, BSB60407 Advanced Diploma of Management Provide its revised training and assessment strategies that meet the training package requirements, study commitment requirements for international students and physical resources (particularly articulating any specialist resources for the above qualifications. The revised training and assessment strategies prepared for the three business qualifications now include reference to: the resources required to produce complex documents; the minimum, classroom time required for international students and that the target group of clients is international students. The strategies provided now meet the requirements of the Training Packages. Page 5 of 35

6 15.3 Staff, facilities and 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.. CPC30611 Certificate III in Painting and Decorating The RTO s Trainers /assessors industry skills matrix did not include the industry skills currency for the core unit of competency CPCCCM2008B Erect and dismantle restricted height scaffolding. Provide evidence of industry currency for the skills to deliver and assess the unit of competency CPPCCCM2008B Erect and dismantle restricted height scaffolding for the following trainers/assessors: Peter Rushen, Kanchan Bhanot, Sandeep Sharma and Minakshi Shori The provider produced revised documents detailing information that the four instructors: held the Certificate III in painting and decorating; held the scaffolding unit CPCCCM2008A Erect and dismantle restricted height scaffolding had current industry work experience working in the painting and decorating industry using scaffolding. Page 6 of 35

7 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 Quality 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.. CPC30611 Certificate III in Painting and Decorating. All trainers/assessors are identified as conducting training and assessment against the whole qualification; however, the document on each trainer/assessor file Assessor/Trainer Self-Assessment did not include evidence of currency against the unit of competency CPCCCM2008A Erect and dismantle restricted height scaffolding. Provide evidence of currency for each of its trainers/assessors listed, to conduct training and assessment against the unit of competency CPCCCM2008A Erect and dismantle restricted height scaffolding. The provider produced revised documents detailing information that the four instructors: held the Certificate III in painting and decorating; held the scaffolding unit CPCCCM2008A Erect and dismantle restricted height scaffolding had current industry work experience working in the painting and decorating industry using scaffolding. Page 7 of 35

8 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.. CPCCM2008A Erect and dismantle restricted height scaffolding Within the CPC30611 Certificate III in Painting and Decorating The Assessments evaluated did not give instructions to the learner or the assessor regarding timeframes for the conduct of an assessment, for example, the erecting of scaffolding has no instruction for the assessor or learner regarding how long a student should take to complete the assessment task. The organisation has not retained any evidence of practical exercises undertaken other than a comprehensive checklist where the assessor/s only state against each of the activities that the exercise was to erect scaffolding with an outcome comment at the completion of the checklist stating 'good'. There was no consideration given to contingencies such as various conditions under which scaffolding may need to be erected for example; sloping or unstable ground etc. Further, the checklists evaluated at audit did not give confidence that they had been completed at the time of assessment rather, on each occasion they gave the appearance of having been ticked in a hurry and each exercise completed at the same time. BSB40507 Certificate IV in Business Administration, BSB51107 Diploma of Management, BSB60407 Advanced Diploma of Management, The assessment instruments evaluated at the audit site visit met the requirements of the relevant unit of competency; however, on each occasion the student files examined only included the theory testing, with a checklist for determination of satisfactory against the projects to be completed by each learner. The organisation s representative stated that the completed projects are not kept on student files, but they are stored at the organisation's main site at A Beckett Street Melbourne. These assessments were provided to the Lead Auditor for evaluation at the visit to the Sunshine campus site on Monday 25 March However, out of 20 student files examined only 1 of the students sampled could be matched to the project assessments. The majority of the assessments did not contain: the assessors signature to identify the assessor; a comment field to provide feedback to the learner; Page 8 of 35

9 the date the assessment was completed; the student s name; and the units name or identifier Therefore, the assessments evaluated at the audit site visit for all qualifications did not meet the rules of evidence in that they were not sufficient, valid, authentic and current. Provide the following evidence for: The unit of competency CPCCM2008A Erect and dismantle restricted height scaffolding. All assessment instruments used to include clear instructions for assessors and learners regarding the type of scaffolding exercise the student is to conduct and under what variable conditions including the timeframe for completion of the practical task to evidence competency. Implement a process to ensure assessors complete the practical observation checklists at the time of assessment and make relevant comment where required and provide feedback to the learner. Leaving the comment column blank and a final comment of 'good' is insufficient to identify why the assessor made a determination of satisfactory/competent for the unit of competency. Provide for the BSB40507 Certificate IV in Business Administration units of competency: o BSBWRT401A Write complex documents, BSB60407 Advanced Diploma of Management, units of competency o BSBFIM601A Manage finances and o BSBMGT616A Develop and implement strategic plans. evidence of assessments against each unit of competency which align to the checklist on the student files and the relevant training and assessment strategy. Provide the process implemented by the organisation to ensure that each assessment includes a cover sheet to record the: the assessors signature to identify the assessor; a comment field to provide feedback to the learner; the date the assessment was completed; the student s name; and the units name or identifier. The two assessments used to assess the unit CPCCCM2008 Erect and dismantle restricted height scaffolding, included clear instructions for assessors and learners regarding the type of scaffolding exercise the student is to conduct and under what variable conditions including the timeframe for completion of the practical task to evidence competency. The provider produced the assessments from 15 students covering the requested units, all of which included the use an appropriate cover sheet which covered the five requirements identified in the above rectification request. However, it was noted that Question 10 in Assessment 4 to assess the unit BSBFIM601A Manage Finances for the student Kulbir kaur was answered incorrectly but marked as correct. (Source, compared to 4 other answers and to a model answer found at: ) Page 9 of 35

10 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 NVR registered training organisation continuously improves client services by collecting, analysing and acting on relevant data. Page 10 of 35

11 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.. Page 11 of 35

12 16.4 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 Learners receive training, assessment and support services that meet their individual needs.. The provider is not addressing the needs of learners prior to the commencement of the training in that a high percentage of students are enrolled in qualifications similar to those already obtained without any apparent regard for credit transfer or RPL. 70% of a sample of 30 students currently studying were identified as currently holding more than 4 qualifications prior to commencing their current period of study and yet no RPL or credit transfer was provided at the audit. Page 12 of 35

13 One student (Immigration student ID ) was simultaneously studying at 2 providers for 18 months between October 2011 and April How were the needs of this student assessed, managed and supported when each course required a minimum of 20 hours per week of study. Demonstrate that the provider has a rigorous process in place to: assess a student s past academic record and assess the credit transfer and RPL available to each student currently studying at the RTO. The provider has revised its enrolment procedure to include the assessment of a student s prior education achievements at the time of enrolment to assess any possible credit transfers or RPL. The provider has also demonstrated where they have provided 2 examples of where Credit transfer has been applied in the past and has issued letters (sighted letter to Bikramjkit Bikramjit) to all possible current students who may be eligible for credit transfer for some of the units in which they are currently enrolled Learners have timely access to current and accurate records of their participation and progress.. Page 13 of 35

14 16.7 The NVR registered training organisation provides appropriate mechanisms and services for learners to have complaints and appeals addressed efficiently and effectively.. Page 14 of 35

15 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 NVR registered training organisation uses a systematic and continuous improvement approach to the management of operations.. Page 15 of 35

16 17.3 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.. Page 16 of 35

17 17.4 The NVR registered training organisation manages records to ensure their accuracy and integrity. The RTO did not manage its records to ensure their accuracy and integrity. The student assessments audited frequently did not contain: the assessors signature to identify the assessor; a comment field to provide feedback to the learner; the date the assessment was completed; the student s name; and the units name or identifier. And hence these could not be authenticated. Six examples of class rolls were sighted at audit for the groups 6C batchs 3-7 none of the documents had the date and time the roll had been taken or the signature of the trainer The original timetable provided to the lead auditor: had typographical errors in it showing that it was not a document in regular use, e.g. The combined group 6KM was also recorded on the timetable as 6KN ; The groups 6R and 4A were both listed as using the room D2 at 9:00am on a Tuesday morning. The timetable provided on 21 March 2012 for the painting and decorating groups showed that 90 students were expected at the Sunshine premises on Monday 25 March At the Monday visit the CEO told the auditors that the group 7MN was on their Easter break and that group 7DE should have been recorded as being present between 1-5pm rather than 9-1pm. These errors show that these timetables were not managed to ensure their accuracy and integrity. A total of 39 students had their CoE status recorded on the CRICOS register as Finished, and yet these individuals were also recorded as commencing the same course within a few days of the completion, indicating that they were not correctly recorded. Demonstrate the process implemented to ensure that each assessment includes sufficient information to record the: Name of the candidate; The unit name and code that the assessment is for; The date the assessment is completed; The name of the assessor and Feedback to the candidate. Page 17 of 35

18 Provide accurate copies of the timetables for the City and Sunshine premises. Provide a copy of a new roll template which includes the: Date the roll was taken; The times the roll was taken and The signature of the trainer The provider is to ensure that the records on the CRICOS register for studying students are accurate. The provider produced examples of assessments from 15 students which included a cover sheet with the required rectification information. The provider produced examples of updated timetables which were free of errors and contradictions. The provider has updated its class rolls to include the date and time taken together with the trainer s signature. The provider has updated its procedures for its PRISMS Administrator to follow. It has also scheduled an internal audit of its ESOS requirements for September Page 18 of 35

19 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 provider s chief Executive had not ensured that processes were in place to ensure compliance with the VET Quality framework as demonstrated by the non-compliances detailed within this report. rectify the issues described within this report. The provider has rectified this non-compliance through addressing all of the issues raised within this report 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.. Page 19 of 35

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21 SNR 19: Interactions with the National VET Regulator 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 by 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 National VET Regulator s requirements.. Page 21 of 35

22 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 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.. Page 22 of 35

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24 SNR 21: Insurance 21.1 The NVR registered training organisation must hold public liability insurance throughout its registration period.. Page 24 of 35

25 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 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 nonrefundable 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. Page 25 of 35

26 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 [Not available] (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 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 (e) (Option 5) the NVR registered training organisation has alternative fee protection measures of equal rigour approved by the National VET Regulator. [Option not available] Fee protection option/s nominated by organisation: Not applicable Option 1 Option 2 Option 3 Option 4 Option 5 Page 26 of 35

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28 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 its current conditions of use The NVR registered training organisation must recognise the AQF qualifications and statements of attainment issued by any other RTO.. Page 28 of 35

29 23.3 The NVR registered training organisation must retain client records of attainment of units of competency and qualifications for a period of 30 years.. Page 29 of 35

30 23.4 The NVR registered training organisation must provide returns of its client records of attainment of units of competence and qualifications to the National VET Regulator on a regular basis, as determined by the National VET Regulator The NVR registered training organisation must meet the requirements for implementation of a national unique student identifier.. Page 30 of 35

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32 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 NVR registered training organisation must use the NRT logo only in accordance with its conditions of use.. Page 32 of 35

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34 SNR 25: Transition to Training Packages/expiry of VET accredited courses 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 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.. Page 34 of 35

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Continuing registration as a national VET regulator (NVR) registered training organisation (RTO)

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