Episode Transcript
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Speaker 1 (00:06):
Welcome to the RTO
Superhero Podcast.
With me, angelaConnell-Richards and Lauren
Hollows.
Welcome back, lauren.
Great to have you back on boardagain.
It's been a little while.
Speaker 2 (00:20):
Yeah, it's like
getting back on a bike with
friends, that's right.
It's all good, yeah, as long asI'm getting back on a bike with
friends.
That's right.
Speaker 1 (00:25):
It's all good.
So in today's episode, Laurenand I thought we would follow on
from the theme that Maycheckand I had in our last podcast
and discuss our first auditunder the new standards.
So, Lauren, how many auditshave you done so far under the
new standards?
Yeah, so we've had three.
We've had two initialregistrations.
Um, uh you, how many auditshave you done so far under the
new standards?
Speaker 2 (00:45):
Yeah, so, um, we've
had three.
We've had two initialregistrations um and then also a
CRICOS, uh slash, rto, uh uhrenewal um re-registration, and
then we've just had a couple ofinteractions um from like
compliance monitoring activitiesthat we're continuing on from
from, you know, before thefinancial year.
Speaker 1 (01:07):
Yeah, yeah, okay, so
we've had one.
So we had an initialregistration for RTO and CRICOS
and it went really well.
We provided some additionaldocumentation prior to the audit
and we had the opening meetingon a Friday, closing meeting on
(01:28):
the Monday and we hadregistration by the Friday.
So I was pretty happy with that.
But we've also heard somestories about people who are
still waiting to get even calledup about an audit because of
the training products thatthey're putting on their scope.
But we can talk about that abit more later.
Let's start with what was yourexperience, because I've already
(01:49):
discussed this my case.
I'd like to know what yourexperience has been with the
three audits that you've had sofar, in particular, any
differences between those aswell, or consistency.
So go for it.
Speaker 2 (02:06):
So I mean, look, in
terms of registration or
re-registration, I thinkobviously those are always going
to be very differentexperiences, regardless of, you
know, the standards that weoperate under.
The two initial registrationswere really.
One of the things that I didsee was there was a lot of focus
(02:26):
on outlining the qualitypractices that the auditors had
to go through.
So they spent a lot of timespeaking to the CEOs and
basically saying this is theprocess that we're going to go
through.
I've already reviewed yourdocumentation.
Now we're going to have adiscussion, then I'm going to
take that back, I'm going towrite up my final report, then
(02:47):
I'm going to sit with anotherassessor.
We're going to go through thatreport together.
If we both come to the sameconclusion, we're going to make
a referral, then that referralis going to be reviewed and then
a decision will be made.
So they were really good aboutcommunicating the different
steps in the process and whatwould happen, you know, if there
was a non-compliance found.
Obviously, there was a verystrong focus, so they did allow
(03:09):
me to participate in all of theaudits.
However, they were very clearat the very beginning to say we
are happy for your consultant toparticipate in these things.
However, you as the CEO, you asthe people in the meeting, are
actually the ones who are goingto be running the RTO.
So we want to hear what you say, we want to hear how you are
(03:32):
going to run the organization,and I think that was really
important.
One of the questions that theygot was how did you come to a
decision about who you used as aconsultant?
So that I thought was veryinteresting, because they
basically said like, whatprocess did you go through to
determine, you know, who youwould use as a consultant?
(03:53):
Were they sufficientlyqualified?
They asked whether or not theychecked my qualifications.
So I think that's a greatpractice to see happening,
because obviously there are RTOconsultants out there that go
and kind of sell like RTO in abox.
They don't want the client tobe really involved in the
(04:13):
process.
I think you and I operate quitedifferently from that, where
it's like, no, you're going tobe the one answering these
questions.
My role here is to prepare youin how to run your RTO, so
watching a lot of those sorts ofthings come to fruition was
really good to see.
Obviously much stronger focus ongovernance, on risk management,
(04:35):
on how they ensured inclusion.
So questions like you know,what practices do you have so
that you are inclusive?
What are your reasonableadjustment processes?
You know, do you have processesin place to support your First
Nations students and staff?
How do you respond to thingslike sorry business, all of
(04:59):
those sorts of things that camemore under the new standards,
that weren't really coveredunder our old standards?
I thought that there was, Imean, in our ones.
There was a lot of focus onthat.
Again, I think part of thatprocess was because they
literally came to us and wentyour TASs are fine, your trainer
matrices are fine and yourassessment tools are compliant.
Had we had non-compliantassessment tools that we'd
(05:20):
submitted, I think the wholeaudit process would have gone
very differently.
In the CRICOS re-registrationspace, there was a huge focus on
PRISMS data, on the managementof PRISMS data, on pulling out a
lot of different reports andthings like that in relationship
to you know when yournon-commencements were lodged,
(05:45):
when your deferrals were lodged,you know if you notified a
commencement, you know a weekafter you were supposed to lodge
the commencement.
So there's definitely a lotmore use of data in terms of the
PRISM system happening and Ithink that we're going to
(06:06):
continue to see that focus.
So you know, we got a list of,I think about four different
types of PRISM breaches and soit was things like you know, you
processed a non-commencement.
You did it, you know, threedays after it was due.
You processed a deferralapplication six weeks after and
(06:29):
so we had to go back anddemonstrate that, you know a
communication process had beenput in place, that there was,
you know, comms happening to thestudent In certain
circumstances.
It was the fact that thestudent had notified us that
they needed a deferral.
But getting the actual evidenceof the compelling and
compassionate circumstances youknow, in one case there was a
(06:51):
parent that had passed away.
Trying to get a deathcertificate from another country
is not an easy process and ittook the RTL a while to get that
documentation.
So we had to provide theevidence of all the emails going
back and forth between thestudents and things like that.
So that has progressivelyincreased in all of my Prisms
(07:12):
interactions.
When we talk about you knowanything in the CRICOS space
with Asqua, they're using thatdata a lot more and I'm actually
finding we're having to do moreand more training and create
more and more like procedures onhow we manage Prisms.
The Prisms user guide is great,but like really having those
(07:34):
checks of you know, like everysix months going and checking
that the students' addresses areup to date.
You know being massivelypedantic on noting the
commencements and thenon-commencements.
You know when you're processingthe refunds, making sure you're
going through all four stagesin Prisms of you know when that
refund was made, the amount thatit was made, the rationale for
(07:55):
it and all of that sort of thingyou know.
Or having all of that data andyou know you've got to train
admin really well to understandit, which is one of the things
that we don't see happeninggreat in the PRISM space.
And in the CRICOS space.
Speaker 1 (08:12):
We've seen quite a
big focus on PRISMs, more so in
the last year, not necessarilyunder the new standards, but
that's very interesting becausewe're in the process right now
of rewriting all of our CRICOSdocumentation to ensure that it
(08:34):
aligns with the standards forRTOs.
So we're just going through allof that now.
But it was accepted in the lastaudit that we hadn't mapped
those yet, so they were fine.
The auditor was fine with that.
But, yes, I'm definitely seeingthat there's more of an
emphasis on how you'reimplementing PRISMS and they're
(08:58):
wanting to see it more in yourpolicies, in your policies and
procedures and your handbooksand things like that.
So, yeah, yeah.
So what was the maindifferences that you found
between?
So you had two initialregistrations.
Was there any differences thatyou had?
Speaker 2 (09:18):
So one was an
external auditor and one was an
internal auditor, so there wassome slight differences in terms
of the approval process betweenone and the other.
Um, however, I will say,outside of that, not really um,
you know both of the, you knowthe, the questions that we got.
They obviously have like a listof questions against every
(09:41):
standard, you know, and they'rekind of going okay, ask, ask
this question, ask this question.
So I'm just, you know, verydiligently going every question
that ask what asks.
I'm writing it down into my bigold checklist, um, and you know
it's.
It's one of those interestingthings like do you want to
release that list so that youcan make sure your clients are
(10:02):
prepared?
But also, you know, it'sprobably good for them to not,
because you know, if you knowyour policies and you know the
standards, whatever question youget asked you should be able to
respond to right.
So I'm going to be a bit toominds on that one.
I think we're going to.
I mean, like in all of theinteractions we've had so far
(10:26):
under the new standards, theasper assessor has been very
clear and kind of going this isall new for us as well.
We're still working our waythrough all of this.
We're still, you know, testingand trialing and figuring out
what the best way is to approachthis because, again, asper
didn't write the standards, diwawrote the standards.
Um, asper was then justresponsible for interpreting
(10:47):
them.
So I think that spirit ofeverything was very good.
That's a completely separateprocess from everything that you
know.
These teams that are going outand shutting down RTOs and
cancelling qualifications aregoing through those two things.
(11:07):
Those two activities are chalkand cheese and different
departments too.
Yeah, we'll just continue tosee.
We'll continue to see that.
You know that, depending on howASQA initially approaches you,
you know, and the mechanismthrough which they approach you,
if your first interaction withASQA is them coming to do a site
(11:31):
visit on you and you'resupposed to have 62 students on
site and you've got three, youknow you're going to, you should
expect a different process.
I'm just going to be honest.
Yes, back to my pride and Ilook, I mean I do like I said.
We had a CRICOS registrationand I'd actually said to the
(11:53):
client I'm like you're in for arough ride Like this is not
going to be easy, and we hadthree or four interactions with
the regulator pre and post thenew standards getting logged,
with the regulator pre and postthe new standards getting logged
.
And then one day I got an emailnotification going traininggov
(12:14):
has been updated and yourapplication's been approved, or
your application's been approvedand traininggov will be updated
.
I got my notification throughAspenNet and I called up a
client and I went you've beenre-registered, and he goes what?
And I went you've gotre-registration.
He goes what.
I was like I'm looking at theemail now and he goes cry, cost
two.
And I was like hold on.
And I was like yep, you've gotit all.
(12:37):
And he was like oh my God.
And I was like yeah, yeah, metoo.
And he was like, oh, thatwasn't as hard as you made it
sound like it was going to be.
I was like, yeah, I know.
Like I'm like genuinely shockeddude.
I was like look, we gave themmore information than they asked
for at every step.
Speaker 1 (12:55):
Yeah, and I think
that really does help.
That's what we did with ourinitial is it said they said if
they got any.
So they had a list of what theywanted and the units that they
wanted to go through and any doyou have any other additional
documents?
So we just did it straight awayand we got provided them with
all the new policies andprocedures, and I think that's
(13:17):
the thing is if you candemonstrate that you're prepared
and ready you can, you're goingto have a much smoother audit,
yeah.
Speaker 2 (13:25):
And like being able
to turn around, like you know,
if somebody asks you for, ifASQA comes back.
I know, in one of our auditsour initials we submitted four
assessment tools.
They came back to us and theyasked us for three additional
assessment tools and they weresent through within, you know,
72 hours or something like that.
I think little things like thatwhere the regulator tests you
(13:51):
and go have you just purchasedthe four units that you
submitted to us or are youactually ready to rock and roll?
Yeah, I think little thingslike that.
Maytech had the same.
Speaker 1 (14:01):
Yeah, maytech had the
same where the auditor asked
for other assessment tools.
Yeah, yeah, and veryinteresting that you had that
one as well, and also what Ifound with the auditor we had.
She definitely did have a listand she actually said I've got
these questions, I've got to ask.
(14:21):
So she went back down throughthe list and just asked all
those questions.
So, uh, so that was goodbecause it was, um, because she
wasn't, uh, focused on just thenew standards, but they had
actually specifically had a listof things that needed to be
(14:41):
covered under the new standards.
So, yeah, so it'll beinteresting to see.
We've've got about another threethat are in for initial and
we've got about five who are upfor re-reg over the next six to
12 months.
So, yeah, it's going to beinteresting to see how it goes.
Some of the other things thatwe've seen is re-regs just going
(15:04):
through and because they'remore focused on other areas,
particularly if you've got alow-risk RTO.
However, they can just do a popaudit at any time in the next,
you know, two years.
So just because you get throughon your re-reg with no audit
(15:25):
doesn't mean it's not going tohappen.
So I would always be prepared.
Speaker 2 (15:31):
Like for me
personally, I would prefer to
see no registration go throughwithout a desktop, even if the
desktop is limited, to send methese five assessment tools,
these three TAS and two trainermatrices of your choosing within
(15:52):
the next 72 hours, right, orwithin the next week.
you know, a really little testlike that for most RTOs is a
really good indicator of whetheror not they have their shit
together, because you can go andlook at their event list and go
well, you delivered thisassessment tool last, like you
(16:13):
delivered that unit in Novemberlast year, right.
And if they turn around and go,oh well, we don't have that, we
don't deliver it.
You can turn around and go,you're, you're full of shit.
What you don't have is acompliant assessment tool that
you want to provide to us, liketo me.
I would rather see that onevery single registration, even
(16:36):
if even if it means you're onlygetting checked once every seven
years.
Having a person dedicated todoing that would provide a
higher level of qualityassurance in the sector, and I
think that should be part of theASQANET process.
Speaker 1 (16:50):
So when you're
submitting your re-reach, you
should have to submit your TASAswith it.
So and then and I would thinkthen the auditors would have a
good idea of whether you'd beready or not auditors would have
a good idea of whether you'd beready or not.
Speaker 2 (17:10):
Yeah, well, I mean
you do.
I mean you submit that.
You submit that spreadsheetwhich says the units you've
deemed competent in the last sixmonths.
Yeah, right, so you know, pick,pick three units that they've
delivered in the last threemonths, pick two student files,
have them submit that.
That'll tell you everything youneed.
Like I mean, that's how you andI do our audits, I'm sure, like
that's what I ask for.
And from that you know, likeI've just done an audit on a
(17:31):
provider.
It took me four times going backto them, like you know, going
this is everything I expect youto upload.
And from the first day I waslike you need to upload your
mapping guides, you need toupload your evidence of your
assessor competency and currency.
But he took a further threeemails of me going mate, these
are the units I'm auditing.
You've given me a mapping guidebut no assessment tool.
(17:52):
Or you've given me assessmenttool but no mapping guide.
You've given me a trainerregistration but you haven't
given me any of their actualdocumentation for me to see that
they've actually got a freakingTAE.
Freaking TAE like I should likeif I go to any compliance
person and say I'm auditing you,put up the documents that I
(18:14):
need to audit it.
Yeah, and the RTO doesn't knowthat they need to give me a
corresponding mapping guide tothe assessment tool and the
certificates for their trainersand assessors.
Speaker 1 (18:26):
It's a red flag yeah,
yeah, yeah, yeah, and it
definitely can show where,whether they're ready or not and
whether they um.
So what I find, when someone uhcomes to us for an audit, they
know they're non-compliant.
They just don't know hownon-compliant they are.
They don't come to us becausethey think they're non-compliant
.
They just don't know hownon-compliant they are.
(18:47):
They don't come to us becausethey think they're compliant.
So it's very interesting andyou can tell by the conversation
and by your initial list ofdocuments that you request
whether they're going to beready or not.
Yeah, yeah, definitely, allright, so my time has gone up.
So thank you very much, lauren,for being here today and
(19:12):
sharing with us your valuableinsights into what you've
experienced so far under the newstandards in audit.
And, as per usual, it's alwaysa pleasure to have you join me
on the RTO Superhero Podcast.
Thank you, thanks, angela, havea great day.
Thank you, usual, it's always apleasure to have you join me on
the rto superhero podcast thankyou, thanks, angela.
Have a great day thank you,there we go awesome.