Causes of non-compliance and strategies to manage the risk
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- Hugh Ramsey
- 7 years ago
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1 RISK & Strategy (Policy & Procedure) The college/company maintains procedures that provide it with a simple but systematic view of the risks it faces in the course of its activities. Risk is the chance that an even will occur that will adversely impact on the college and company objectives, as listed in its business plan (Ref: OPSP (One Page Strategic Plan)). It is measured in terms of adverse consequences and likelihood. Risk is the process used to determine risk management priorities by evaluating and comparing the level of risk against acceptable levels of risk. Because of commercial -in - confidence issues the risk process may not be available as a public document. Risk management involves the systematic application of management policies, procedures and practices, which identify, analyse, assess, treat and monitor risk. The risk management process may be an informal process or may be part of a more formal business planning process. Everyone in the college and company is responsible for effective management of risk. All staff are responsible for identifying potential risks. Refer to this link for RTO Risk (AQTF & National Code) policy and procedures - Risk Policy (RTO) Included below are the 2 main Risk & Matrices, AQTF & National Code. Please refer to these when conducting internal/external audits. AQTF 2007 Standard & National Code Standards 1.The Registered Training Organisation provides quality training & across all of its operations 2. The Registered Training Organisation adheres to principles of access and equity and maximises for its clients 3. systems are responsive to the needs of clients, staff and stakeholders, and the environment in which the Registered Training Organisation operates Staff External Parties Eg: Suppliers, Stakeholders, Clients Facilities and Equipment IT Systems High Medium Low Low Medium Medium Low Low High Medium Low Low Conditions of Registration 1. Governance High Medium Low Low 2. Interactions with registering body High Medium Low Low 3. Compliance with legislation High Low Low Low 4. Insurance High Medium Low Low 5. Financial High Medium Low Low 6. Certification and issuing of Medium Low Low Medium qualifications and statement of attainments 7. Recognition of qualifications issued Medium Low Low Low by other RTO s 8. Accuracy & integrity of marketing Medium Low Low Low 9. Transition to Training Packages/ High Low Low Low expiry of accredited courses Determine the probability that each source could currently cause non-compliance with each AQTF standard. Note that ranking may change over time and should be reviewed regularly High most likely to cause non-compliance Medium might cause non-compliance Low unlikely to cause non-compliance RISK v2 16/02/2010 Page 1 of 5
2 Causes of non-compliance and strategies to manage the risk Standards 2007 AQTF standards& National Code Source (H/M) List sources assigned a high or medium probability Cause Mitigation Strategy Monitoring Strategy List what List what strategies could List what strategy specifically be put in place that would is currently in about the source reduce the probability of the place to monitor could cause non risk eventuating whether you are compliance to complying with the standard the standard 1. The Registered Training Organisation provides quality training & across all of its operations 1.1 The RTO collects, Participants analyses and acts on relevant Clients data for continuous Trainers improvement of training and Internal Audit 1.2 Strategies for training and meet the requirements of the relevant Training Package or accredited course and are developed in consultation with industry stakeholders Standard 7 Transfer between Registered Provider Standard 9 Completion within expected duration 1.3 Staff, facilities, equipment and training and materials used by the RTO are consistent with the requirements of the Training Package or accredited course and the RTO s own training & strategies 1.3 Training and are conducted by trainers and assessors who: a) have the necessary training and competencies as determined by the National Quality Council or its successors, b) have relevant vocational competencies at least to the level being delivered or assessed 1.4, including Recognition of Client Trainers tool Developers Head Trainer & Assessor Assessors, The RTO does not act on feedback from any of these sources, and does not seek to improve its processes/ material Material/ created in isolation & without consultation/ approval from relevant stakeholders Use of Non Approved material could lead to inappropriate/ inadequate material/ being used Engagement of non qualified/ experienced staff (trainers) Inexperienced personal Surveys are conducted upon completion of course. Feedback is sought in regular basis from clientele/ staff Internal Audit process is ongoing throughout the year All material/ is created in house or externally Input/ review from client is both sought & acted upon prior to obtaining final approval. Whilst material is in Draft Format it is held by developers (internal or external), only once material has been approved for use, it will be made available Majority of staff (trainers) engaged by the college/ RTO hold either BSZ or TAA (or relevant) qualifications. Those individuals without formal qualifications, but with relevant experience must attain formal qualifications within 6 months of the employment commencing. All staff engaged must demonstrate the relevant industry experience/ formal vocational qualification prior to being offered employment All RPL applications are to be documented Surveys are received and date stamped, any comments tabled at Meetings. Feedback from clients is sort during regular meetings with representatives from Sales & All material is viewed by before release to ensure compliance tool developers and and s work collaboratively to ensure that only correct material is used These staff will be supervised directly by the (or their designate) until such time as the qualification & experience is attained/ demonstrated Are to be validated by Contingency Strategy What would you do if you learnt you were not complying with the standard Manager / and the Manager / would Manager / and CAIO would Manager / and or CAIO RISK v2 16/02/2010 Page 2 of 5
3 Prior Learning (RPL) a) meets the requirements of the relevant Training Package b) is conducted in accordance with the principles of and the rules of evidence endeavouring to undertake RPL, could result in non-compliance due to inappropriatenes s and validity of evidence. or their designate), and results provided to applicant using prescribed would c) meets workplace and where relevant, regulatory requirements 2. The Registered Training Organisation adheres to principles of access and equity and maximises for its clients 2.1 the RTO continuously improves client services by collecting, analysing and acting on relevant data Training services become stagnant, and outdated Regular communication with all parties 2.2 Before clients enrol or enter into a contract, the RTO informs them about the training, and support services to be provided, and about their rights and obligations Standard 1- Information & Practices Standard 2 Engagement before Enrolment Standard 3 Formalisation of Enrolment Standard 4 Education Agents Standard 12 Course Credits 2.3 Employers and other parties who contribute to each learners training and are engaged in the development, delivery and monitoring of training and Standard 8 Complaints & Appeals 2.4 Learners receive training, and support services that meet their individual needs Standard 4 Formalisation of s Clients Assessors Managemen t Team ( ) s Client Managers, Group Manager, Sales & Director Tool developers IAB Board meetings Uninformed student who does not know/ understand their rights & responsibilities, nor what qualification/ units they are undertaking Material/ created in isolation & without consultation/ approval from relevant stakeholders Learning needs, special needs, issues not recognised/ addressed could result in not completing qualification Each is provided with an Handbook at the Orientation meeting, and all aspects are covered & explained by Manager/ or designate All material/ is created in house or qualified external developers Input/ review from client is both sought & acted upon prior to obtaining final approval. During discussions with students, potential needs issues are discussed, and if necessary appropriate amendments made to training methodology s are surveyed upon completion of course Feedback is attained throughout course by Assessors/ Additional feedback is sourced by Sales & Department in regular communications with client Reviewed by annually All material is viewed by before release to ensure compliance At first visit, student is required to complete which is used to ascertain literacy levels. If additional RISK v2 16/02/2010 Page 3 of 5 Manager / and or CAIO would Manager / would Manager / would immediately what additional support services would be required, and report back to next Manager / or designate and
4 Enrolment Standard 6 Support Services Standard 7 Transfer between Registered Providers Standard 13 Deferment, Suspension or Cancellation of Study 2.5 Learners have timely access to current and accurate records of their participation and progress Standard 9 Completion within expected duration Services Officers Manager/ s may require details of progress for a variety of reasons Under privacy act, information cannot be released without written consent of the actual participant assistance is required/ requested then matter is forwarded to National Training Manager Statement of attainment, access to information pertaining to training can be requested at any time by the student in writing. Original training documents are not to be issued, only copies of, however originals can be sighted within the offices of the college/ RTO All requests pertaining to access/ issue of records to be in writing or designate 3. systems are responsive to the needs of clients, staff and stakeholders, and the environment in which the Registered Training Organisation operates 3.1 The RTO uses a Meeting systematic and continuous Minutes are reviewed improvement approach to the at each meeting, and management of operations. all action items are reported on/ updated Standard 15 Changes to Registered Providers Ownership or 3.2 The RTO monitors training and/ or services provided on its behalf to ensure that they comply with all aspects of the AQTF 2007 Essential Standards for Registration Standard 10 Monitoring Course Progress 3.3 The RTO manages records to ensure their accuracy & integrity Standard 10 Monitoring Attendances s, College/ RTO Staff Manager, Head Trainer Assessors team meets on a regular basis (fortnightly minimum) and any matter involving the business activities is discussed and documents such in the Meeting Minutes N/A N/A The college/ RTO does not engage in 3 rd Party activities, all staff are permanent members of staff and or permanent contractors All administration processes are heavily audited (internally) to ensure compliance is maintained across all operations RISK v2 16/02/2010 Page 4 of 5 N/A Manager / & CAIO to and Meeting If such an occasion was to arise the monitor and report back to next Meeting Manager /, CAIO would Conditions of Registration 1: Governance The College/RTO s PEO must ensure that the RTO complies with the AQTF 2007 Essential Standards for Registration and any national guidelines approved by the National Quality Council. This applies to all of the operations within the RTO s scope of registration, as listed by the National Training Information Service. Through the National Team, all RTO activities adhere to relevant standards. A Compliance Assurance & Implementation Officer is appointed and responsible. 2: Interactions with the registering body The College/RTO s PEO must ensure that the RTO cooperates with its registering body: In the conduct of audits and monitoring of its operations. By providing accurate and timely data relevant to measures of its performance By providing information about significant changes to its operation. In the retention, archiving, retrieval and transfer of records consistent with its registering body s requirements. The PEO is the immediate point of contact between RTO and all VET registering bodies. Internal Audit Schedule prepared and reviewed annually, and findings reported to/ minuted at regular management meetings. 3: Compliance with legislation The RTO must comply with relevant Commonwealth, State or Territory legislation and regulatory requirements that are relevant to its operations and scope of registration. It must ensure that its staff and clients are fully informed of requirements that effect their duties or participation in vocational education and training. Compliance & Assurance Implementation Officer (CAIO) and the oversee the compliance with relevant legislation. Sales &, Support (Admissions) departments are tasked with informing students/clients of their responsibilities by involving their staff in training programs 4: Insurance The RTO must hold insurance for public liability throughout its registration period. The PEO and Directors of the college/rto, organise on an annual basis all insurance coverage, including Building & Contents, Workers Compensation, Public Liability & Professional Indemnity. Details are retained by the Group Accountant
5 5: Financial The College/RTO must protect fees paid in advance and have a fair and reasonable refund policy. The College/RTO must have its accounts certified by a qualified accountant to Australian Accounting Standards at least annually, and must provide the certificate of accounts to its registering body on request. If the registering body reasonably deems it necessary, the PEO must provide a full audit report on the RTO s financial accounts from a qualified and independent accountant. The PEO has overall responsibility to ensure that the College/ RTO comply with financial management policies. The College/ RTO s accounts are audited annually by a qualified accountant (who has membership with the Certified Practising Accountants Australia, or the Institute of Chartered Accountants of Australia). A copy of the audit report conducted by a qualified accountant will be made available to the relevant State Training Registering Body upon request. The audit report is retained by the Group Accountant and his/her department 6: Certification and issuing of qualifications and statements of attainment The College / RTO must issue to persons whom it has assessed as competent in accordance with the requirements of the Training Package or accredited course, a qualification or statement of attainment (as appropriate) that: Meets the Australian Qualifications Framework (AQF) requirements. Identifies the RTO by its national provider number from the National Training Information Service Includes the Nationally Recognised Training (NRT) logo in accordance with the current conditions of use. The RTO must retain learner records of attainment of the units of competence and qualifications for a period of 30 years. All paper-based is held onsite for 12 months post completion prior to being transferred to suitable storage facility, and all electronic data is suitably maintained and stored in appropriate location. 7: Recognition of qualifications issued by other RTO s The RTO must recognise the AQF qualifications and statements of attainment issued by any other RTO. Upon receipt of Statement of Attainments, or Statement of Results (originals or verified copies only) issued by another RTO, the college/rto will grant automatic exemption/ credit to participant. Credit will be recorded on the participants Statement of Attainment issued by the RTO. 8: Accuracy and integrity of marketing The College/RTO must ensure that its marketing and advertising of AQF qualifications to prospective clients is ethical, accurate and consistent with its scope of registration. The NRT logo must be employed only in accordance with its condition of use. The College/ RTO does not state or imply that courses other than those on its Scope of Registration are recognised by the relevant State/ Territory Authorities. 9: Transition to Training Packages/ expiry of accredited courses The College/RTO must manage the transition from superseded Training Packages within 12 months of their publication on the National Training Information Service. The RTO must also manage the transition from superseded accredited courses so that it delivers only currently endorsed Training Packages or currently accredited courses. High = most likely to cause non-compliance Medium= might cause non-compliance Low = unlikely to cause non-compliance RISK v2 16/02/2010 Page 5 of 5
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