Scope Trap: Why Expansion Can Trigger Audit Disaster

In this timely episode, Angela Connell-Richards explores the compliance risks that come with adding courses to your RTO’s scope—especially under the 2025 Standards. What seems like growth can quickly turn into an audit nightmare without the right preparation.

Key points discussed:
 ✅ The audit risks tied to scope additions and amendments
 ✅ How to pre-assess your readiness before submitting a scope application
 ✅ The evidence ASQA looks for when reviewing new course delivery
 ✅ How to align your TAS, trainers, and resources before expansion

Angela helps you build a proactive process for safe, strategic scope growth—without putting your registration at risk.

Listen now and download Angela’s free Scope Expansion Readiness Tool to audit-proof your next course launch.

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 Join host Angela Connell-Richards as she opens each episode with a burst of insight and inspiration. Discover why compliance is your launchpad to success, not a limitation. 

Wrap up with gratitude and guidance. Subscribe, leave a review, and join our community as we continue supporting your compliance journey in vocational education. 

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Episode Transcript

Speaker 1 (00:02):
Welcome back superheroes.
You're listening to the RTOSuperhero Podcast with me,
angela Connell-Richards, yourcompliance guide, vet, system
strategist and cheerleader forsustainable, quality-driven
growth in your RTO.
Today, I want to speak to youabout something that might seem
like an exciting step forwardbut can actually derail your

(00:24):
entire organisation if it's notdone right.
We're talking about adding toyour scope of registration and
why it's one of the biggestaudit traps in the game.
Now adding a new course orqualification might look like
progress, but if you're notcareful, it can quickly escalate
into a compliance disasterunder the new standards.

(00:46):
So in today's episode, I'mgoing to walk you through the
real audit risks behind scopeadditions, what ASCO is looking
for, how to self-assess yourreadiness and what evidence you
need to have locked in beforeyou hit submit If you're
planning to grow your offeringsin the next six to 12 months.

(01:08):
This is a must listen.
Section 1, why scope changestrigger audits.
Now let's start with the bigshift.
Under the old framework,additions to scope were usually
managed with a quick desktopreview by ASQA, but now, with
the 2025 standards andrisk-based assessment model in

(01:30):
place, any scope change cantrigger a full audit.
Well, why is this, angela?
Because ASQA sees a new courseas a change to your service
model, a shift to in-learnercohort and potentially a
completely different riskprofile.
If you're delivering a businesscourse and suddenly apply to

(01:54):
deliver a CRICOS cookery program, asqa is not going to just wave
through with that one.
They're going to ask do youhave the right trainers?
Is your TAS robust andcontextualised for international
students?
Are your facilities compliance?
Do they meet 9b requirements?
Is your industry consultationup to date in particular,

(02:18):
focused on targetinginternational students and
education and facilitiesoverseas?
This is where many RTOs falldown.
They assume we've got the formsfilled in, we'll be fine.
But forms aren't evidence andgrowth without infrastructure is
a red flag.

(02:41):
Section two the top risks tiedto scope additions.
Let me break it down into thebiggest audit triggers I see.
When RTOs apply for anexpansion to scope, incomplete
or generic TAS documents, youneed to show that your training
and assessment strategy iscustomised to the learner cohort

(03:02):
, mapped to actual deliveryresources, supported by trainers
with current relevantexperience and expertise.
Asqa wants to see depth, notrecycled templates, unqualified
or underprepared trainers.
If the trainer you've listedfor the course doesn't have MAP

(03:24):
competency, vocationalcompetency, recent industry
experience, a compliant TAEqualification, you'll likely be
asked for more evidence or haveyour application denied outright
.
No evidence of industryconsultation the 2025 standards

(03:45):
require documented, relevant andrecent consultation with
employers, industry bodies andor professional associations.
Saying we know the industryisn't enough.
You need emails, meeting notes,feedback summaries,

(04:05):
misalignment between courseclaims and capacity.
If you say you're delivering100% online but don't have an
LMS that supports simulation orassessment validation, you'll be
asked to explain.
Same goes for on-campusdelivery with no documented
access to compliant facilities.
Section three how to pre-assessyour scope readiness.

(04:30):
Now don't stress scope.
Changes can be done well, youjust need to think like an
auditor.
Here's my scope expansionreadiness framework.
Step one TAS audit.
Is your TAS tailored to thecourse and the learner cohort?
Have you clearly listed theassessment methods, delivery

(04:53):
mode, resources and supportstrategies?
Are all trainers mapped to theunits of competencies that
they're going to deliver?
Step two trainer file review.
Does your trainer have mappedvocational competency?
Is their industry currencydocumented and recent?

(05:13):
Do they meet the credentialpolicy requirements?
Step three resource alignmentrequirements.
Step three resource alignment.
Are your learning andassessment tools mapped to the
current version of the trainingproduct?
Do you have access to allresources mentioned in the TAS?
Have these tools been trialledor validated.

(05:36):
Step four facilities check.
If applicable.
Are your delivery locationscompliant with WHS and
accessibility requirements?
Do you have enough physicalresources, equipment, labs,

(06:01):
tools to support the number oflearners?
Step five industry evidence.
Have you gathered at least tworecent examples of industry
consultation?
Can you show how that feedbackinfluenced your TAS or
assessment design?
Once all of these areas fiveareas are covered, you're in a
strong position to proceed.
Section 4, what ASQA wants tosee in a scope application.

(06:24):
Let's zoom in on what ASQA willexpect when reviewing your
application.
They'll want to see a detailed,contextualised task map,
trainer credentials to each unit, assessment tools that reflect
valid, current and sufficientevidence.
Evidence of consultation andlearner support strategies.

(06:47):
Clear identification offacilities and learning
environments.
If anything looks rushed orgeneric, you'll be asked for
clarification or it'll getflagged for audit.
The goal here is alignment.
Everything must tell the samestory that your RTO has planned,

(07:09):
resourced and consultedeffectively for this new
delivery area.
Section five a quick clientstory the cost of rushing a
scope.
Let me give you an example.
We worked with an RTO let'scall them Pacific Skills Academy
.
They submitted a scope ofapplication for a new community

(07:32):
services qualification.
They had the TAS, they hadtrainers.
They had enthusiasm, but theirtrainer hadn't worked in the
sector for over five years.
The TAS was a repurposed onefrom a different course and they
had no documented industryconsultation.
Asqa knocked back theapplication and flagged them for

(07:55):
a broader compliance review.
That's right.
They came in and they destroyed.
The good news is we helped themrebuild their scope application
properly and six weeks laterthey were approved.
Lesson do it once, do it right.
Section 6, free tool ScopeExpansion Readiness Checklist.

(08:18):
To make things easier for you,we've put together a free tool
Scope Expansion ReadinessChecklist.
To make things easier for you,we've put together a free
download the Scope ExpansionReadiness Tool.
This document walks you throughTAS review questions, trainer
credential checks, industryconsultation, logging facilities
and resource evidencesubmission prep steps.

(08:39):
You can use it to access,assess your current readiness,
identify any risks, prepare fora clean, confident application.
Download it at vivacitycomau orcheck the link in the show
notes.
So you've got plans to growyour RTO in the second half of

(09:00):
2025.
Remember every scope change isa compliance checkpoint.
Approach it like you're alreadybeing audited and you'll pass
with flying colours.
Audit your TAS, validate yourtrainer files, document
everything and use the readinesstool to stay ahead of the game.

(09:23):
Thanks for joining me today onthe RTO Superhero Podcast.
Next week we'll shift gears andtalk about high-risk training
products and what to do ifyou're delivering one of ASQA's
top-watched quals.
Until then, stay compliant andkeep thriving.