Episode Transcript
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Angela Connell-Richards (00:17):
Welcome
, superheroes, to another
episode of the RTO SuperheroPodcast.
I'm your host, angelaConnell-Richards, and today
we're diving into the hot offthe press revised standards for
RTOs, which were released onFriday, the 14th of March, and
joining me is the amazingco-host, lauren Boone-Hollows,
(00:39):
an expert in RTO compliance andadvocate for quality training
outcomes.
Together we're breaking downthe changes and what's going to
be the impact on RTOs and whythese changes matter and what
they mean to you as an RTO ownermanager.
Compliance officer.
Lauren, welcome back.
Thank you very much for havingme.
(01:02):
It's always awesome having youhere, lauren.
I love having our chats, um andparticular, because we just
love compliance so much.
We're crazy, but anyway, okay.
So what were you, what wereyour initial thoughts when they,
when the standards dropped onfriday?
Lauren Boon-Hollows (01:20):
um, well,
the first thing was okay, cool,
great, they're actually finallyout.
We know that from one 725,we're gonna have to be meeting
this new standard.
Um, which was really, reallygood um, and I do.
What I will say is I do like thethe structure of having the
outcome standards sitting aboveit and then having the
performance indicators sittingbelow it.
(01:42):
I I know that ASQA was workingwith the legal team on refining
the instrument for quite a longtime and I think that that
particular structure and theyhave you can see work that's
been done in order to try andmake those performance
indicators clearer for RTOs sothat they do have something you
(02:05):
know very clear to work to, andcertainly I think that that
particular structure is a lotbetter than just having these
outcome standards, which weredefinitely a lot more like.
They were just far more open tointerpretation.
So I think that you know you'renever going to get anything
(02:26):
perfect, but given all the workthat's been put in, I'm
relatively happy with wherewe've kind of arrived at.
I think that most of this stuffis very workable for RTOs.
Angela Connell-Richards (02:36):
Well,
they've done a lot of
consultation.
Lauren Boon-Hollows (02:38):
So I don't
think I've ever seen so much
consultation on legislation forthe training sector yeah, but it
does have such a huge impact aswell and, like, obviously,
asqa's, asqa's is as impacted byit, by the RTOs who are being
regulated by it.
So I think that, as I said, Ithink what they've come to and
(03:00):
that structure that they've cometo is is a more workable than
what we were initially presentedwith two years ago.
Angela Connell-Richards (03:10):
Yeah,
yeah, definitely.
So there's been a lot of to andfro and I'm glad that they've
taken on board a lot of thefeedback that was received into
the incorporation.
Were there any major surprises,or do these align with what you
were expecting from the draftstandards?
Lauren Boon-Hollows (03:28):
I mean,
look, as I think we've spoken
about before, you and I haveboth been rewriting all of our
policies and procedures,understanding that this is kind
of what we were going to have tobe working with.
I don't see any major changesin that.
I think some of the definitionsthat have come out have been
really good.
It's nice to see that.
I was really happy with, forexample, 1.3.
(03:52):
I just thought the way thatthey put the performance
indicators on 1.3 with veryclearly stating assessment tools
are reviewed prior to use toensure assessment can be
conducted in a way that'sconsistent with the principles
of assessment rules of evidence.
I was.
There's just no question now,right, we're not going to give
some vague definition ofvalidation, pre-validation,
(04:14):
moderation, like somethingthat's just been argued so much.
Um, it just made it very, veryclear that you know with 1.3,
yes, you're going to have tocheck that your tools are going
to be fully compliant, sothere's no excuse for, oh well,
I bought them and I was given aguarantee that they were
(04:34):
compliant.
No, you actually have aresponsibility to make sure that
that's definitely going to bethe case.
And then, after you deliver thetraining, after you deliver the
training, you've got anobligation to make sure that the
assessment practices andjudgments right.
And that word having that wordin 1.5, that you're checking the
judgments that have been madeit just removes all of that lack
(04:58):
of clarity of like before andafter.
So that definitely does have tobe done.
My interpretation of that isbasically you have to review
every single assessment tool andvalidate every single
assessment tool prior to usingit.
And I mean like on a practicallevel.
Why would you not Like, whywould you deliver an assessment
(05:20):
tool that you don't?
Angela Connell-Richards (05:21):
even
know how to use Exactly tool
that you've never looked at,never used Exactly.
Lauren Boon-Hollows (05:25):
So I think
that it's going to be you know,
some of those sorts of thingsfor some RTOs is going to be
really problematic, yeah, andthey're going to be going.
Oh well, we've got, you know,32 qualifications on scope and
we've got over 1,000 assessmenttools and we've only ever bought
them from providers and we'venever actually checked them
(05:45):
ourselves.
Well, that's just not okay.
Angela Connell-Richards (05:50):
One of
the things that I recommend is
and when I was reading into thedraft standards I thought this
would be the best method wouldbe trainers actually complete
the assessment tools so thatthey can see what it's like,
what the process is like, andthen they can get a better
understanding.
Then we can go to validate,because, if you can, if you've
(06:13):
just bought assessment tools,reviewed them, I think, as a
trainer assessor, the best wayyou're going to learn is by
completing the assessmentyourself and then do validation
after that, where you can findout where those gaps are.
And I know as a trainer andassessor myself, I learnt a lot
by just using the assessmenttools when I was delivering
(06:38):
training and, like one of myfavourite sayings is teach to
learn, I learnt so much when Iwas teaching.
Lauren Boon-Hollows (06:47):
Yeah, yeah,
the other part of that as well
is just that you know now whatwe're seeing.
Well, certainly, what I'mseeing a lot of is that RTOs are
then looking to take thesetools and put them into student
management systems, and so youknow that process of putting
them into the student managementsystem and thinking about what
(07:09):
you want the students to bepresented with, how they're
going to engage in things.
I was doing a validation ofsome training materials from
another provider last week andyou know, they kind of just copy
and pasted them into the systemand I was like guys, they said,
with these observations, likewith the practical tasks, I said
like, is a trainer in theclassroom observing them?
(07:32):
Is the student supposed toupload them?
Do them in their own time?
And they were like well, whatdo you mean?
I'm like well, there's like noinstruction.
Like there's no instruction inthere as to, like, how this
practical assessment is actuallygoing to take place, whether
you're going to record it,whether or not it's supposed to
be done in the workplace,whether or not it's going to be
done in simulation.
Like it's just, it just saysyou need to do this, but it
(07:55):
doesn't say how you need to doit.
And they were like oh, and Iwas like, okay, so like part of
this, you know, so part of theupload process, you know,
includes that as well.
And I know that there are othertools out there that you can
buy, where they've kind of triedto give both options of like
well, here's how you're going todeliver it if you're delivering
in a simulation, and here's allof the simulated business that
comes with it, and here's howyou would deliver it in the
(08:17):
workplace.
And it's all built into the onetool.
So the one tool is huge.
It, you know, like it's like ahundred pages because, but it
can be adjusted to the differentit's got.
Yeah, well, I mean the rto ismeant to like review it and then
pull out one of those paths.
Right, they've chucked it allin together and then I'm looking
at, I'm going you've got athree percent completion rate on
(08:40):
your assessment tools, based onwhat your student management
system's telling me.
That's because you've justchucked everything up there,
like there's clearly been noreview of this tool whatsoever
prior to you know, prior toimplementing it.
Angela Connell-Richards (08:54):
So I
think a lot of the big part is
the usability.
Lauren Boon-Hollows (08:58):
The
usability of it, yeah it'd be
compliant and completelyunusable.
True, you know, I mean like youcan develop a compliant tool
that's just not usable becauseof the model of training that
you deliver or because you knowit's so big that students aren't
going to be able to follow itthemselves, and things like that
.
So I do like the way that thestandards are.
(09:20):
I know that Colleen on LinkedInshe raised an issue about 1.4
and she was bringing out thefact that in the wording for
valid so validity under, youknow, rules of evidence now says
assessment evidence is adequateand I totally agree with her
that that particular word,adequate, is problematic Like
(09:42):
what's adequate.
Angela Connell-Richards (09:43):
It
opens up to auditor's individual
opinion on what is adequate.
Lauren Boon-Hollows (09:49):
Yeah, so I
mean, I think that's one of the
you know, that's one of thosewords where I was like, oh okay,
I mean validity before was veryclear.
You covered everything in theunit of competency, like every
part of that unit, and I meankeeping in mind that we're
following on from all of thesenew standards that are coming
out.
We've got a new trainingpackage framework, you know, and
(10:10):
the new training packageframework is going to bring in
potentially a whole newstructure of the unit where
conformance evidence andelements are being kicked out
the door.
Angela Connell-Richards (10:23):
You
know, some of that sort of
language is going to becomequite interesting, yeah yeah,
and have you reviewed all of theadditional documents that came
out with the standards?
So the credential policy,standards policy, and then we've
also got the compliancerequirements.
(10:43):
What are your thoughts on?
Lauren Boon-Hollows (10:44):
the
guidance.
Yes, we did one in the PeopleAct.
Yeah, what are?
Angela Connell-Richards (10:46):
your
thoughts on the guidance?
Yeah, what are your thoughts onthose guidance documents?
Lauren Boon-Hollows (10:51):
So, look,
we all knew the credential
policy was going to remain thecredential policy, so that's.
I think that that's been.
I mean, it's pretty much beenin place since like March of
last year.
Look, I completely.
I actually see both sides ofthis argument.
I understand the people turningaround and saying you're
watering down the requirements,you're allowing people back in
(11:12):
who've only got their tae10 um,and so I can understand you know
the the concerns.
I also see the other side of itgoing.
We've got a massive shortage oftrainers in certain industries.
Angela Connell-Richards (11:25):
Yeah,
and my thoughts on that one is
trainers and assessors.
You don't need, I don't thinkyou should have to do the
qualification again, but I thinkit is very important that you
are doing your vet PD and yourindustry PD.
Lauren Boon-Hollows (11:43):
That's
right.
Trainers don't need to have ASS502.
They don't.
The vast majority of trainersout there train and assess.
They do not design trainingmaterials, and I understood it
at the time.
The thought processes was look,if they know how to write an
assessment tool, they're goingto know how to, you know,
deliver that assessment toolmore completely.
(12:04):
There's going to be less, youknow, pushback between trainers
and developers, but the reality,unfortunately, was that the
vast majority of that trainingwas ticked and flicked.
It was one of the saddest likethings you know, and I ran
several projects working intandem with Mr Wed where, you
know, we contextualised all thetraining for construction
(12:24):
trainers, or we contextualisedall the training for
construction trainers, or wecontextualised all the training
for hospitality trainers.
We took them through theprocess of that cheese and
crackers.
Like you know, I had staff, Ihad my lead developer sitting
with trainers for hours andhours on end to get them through
this unit.
Angela Connell-Richards (12:42):
It's
not their forte.
It's not like that's not theirskill set.
Their skill set is theirindustry.
Lauren Boon-Hollows (12:49):
Yeah, and
the reality is is that for many
of those industries, it's, it's.
They are not paperwork basedpeople, they are focused on
scans on.
So we're pushing people moreand more and I mean, look, don't
get me wrong, you're standingpaper like, you're going to be a
trainer and assessor, you'regoing to have to do paperwork,
you're going to have tounderstand legislation and
(13:11):
compliance and things like that.
But trying to push them into adeveloper box was an absolute
nightmare and I think that we doneed to open it up because we
do have a shortage in ourindustry and we need to be, you
know, we need to allow foradditional options, because
otherwise we're just there'sjust not enough.
(13:33):
There's not enough trainers tobuild the skills that our
country actually needs.
We don't have enoughconstruction trainers to get
construction people out there sothat we can build homes, which
is, you know, clearly a need forthe country.
So I think that you know thisis something that had to be done
.
Angela Connell-Richards (13:50):
There
was just too many barriers to
entering the market as a trainerassessor.
Lauren Boon-Hollows (13:55):
Yeah,
exactly.
And again, as long as you'redoing your regular professional
development, then I think that'sfine.
Think the industry requirementagain, there's people saying
that it's been, you know,watered down and to some extent
I can understand where they'recoming from.
But I also look at it and go,okay, but if you were a trainee,
for you know, if you were atrainee for 20 years and then
(14:20):
you moved into doing um trainingand you are still working on
the tools with the kids on adaily basis and you're going out
into industry and you know youhave a range of strategies in
place, and I mean, in an idealworld, I think RTOs should be
doing like regular kind ofcompetency checks.
(14:41):
You know, I've got an RTOtothat has, I think we've got
about 30 auspice arrangementswith teachers and schools.
We bring those teachers outevery single year, we get them
back on the tools and weactually have industry and our
lead trainer do a currency, likealmost do a voc on them to go
(15:02):
right.
Do you understand?
Like are, are you still able toto perform a weld?
You know that doesn't look likeshit.
Angela Connell-Richards (15:08):
Um,
yeah, so and that's very much
what's in the new vet workforcerequirements under um quality
area three.
So it is very much how.
How are the trainers andassessors getting out of the
classroom and really looking atapplying those skills and how
(15:30):
are they keeping current withthat?
Because the big thing is isthat we need to bring them in to
be able to teach these skillsand if they're not up to date,
that's not going to help.
I love the idea of the well,it's not an idea now.
I love the experts of the well,what's not an idea now?
I love the experts, industryexperts and bringing experts in
that whereby they don't have tohold the cert for and training
(15:51):
assessment, but they're industryexperts where they can discuss
their current skills andknowledge within the industry.
Um, yeah, I think that was areally good component to be
brought in.
So let's break down like sowe've now got our three areas.
We've already talked aboutoutcome standards and the
credential policy, and thenwe've got the compliance
(16:14):
requirements, which I see isjust our general compliance.
So I don't think a lot haschanged.
Lauren Boon-Hollows (16:27):
What did
you think of Clause?
Angela Connell-Richards (16:27):
6,
Previous Conduct and Involvement
.
And that's around fit andproper person requirements.
Lauren Boon-Hollows (16:32):
Yeah, yeah.
Angela Connell-Richards (16:35):
And I
think that's actually good,
because we've actually had a lotof dodgy operators that were
out there and I've seen it wherethey've come to us, where
they've failed initialregistration or re-registration
and I've looked at their auditreport and I'm like OMG, like we
don't want to work with you,but they really needed to be
(16:58):
strict on those fit and properpersons because it was bringing
the industry down.
Those dodgy operators and thereare so many fantastic operators
that are out there.
So what are your thoughts on it?
Lauren Boon-Hollows (17:15):
I agree
with you.
I think that we know thatduring our little VAT student
loans era, I think we also knowthat there are plenty of RTOs
that are very much related inreality and yet for some reason,
on paper they've all got adifferent CEO and everything
like that.
I think that the best strategyfor any RTO is to be very, very
(17:36):
upfront about who you'reconnected with and to be very
careful as to who you'reconnected with.
I think that you know this isgoing to be one of those areas
where I'm going to.
I'm just going to say withgreat power comes great
responsibility.
You know the sorry 6.2 and 6.3and then 7, you know the vet
(17:58):
regulator may have regard towhether a person is previously
engaged in conduct thatreasonably suggested a
deliberate pattern of unethicalbehavior.
The national vet regulator mayhave regard to any other matter
relating to a previous person'sconduct or involvement that the
regulator considers relevant.
The national vet regulator mayhave regard to whether the
(18:19):
public is unlikely to haveconfidence in the person's
suitability to be involved in anorganization.
So it is.
I think it's important for RTOsto understand.
It's a very, very broad.
I know that, like you and Ihave cultivated our connections
and our networks and the peopleand the businesses that we work
with very, very carefully overthe years.
(18:40):
Um, specifically for this reason, my strong recommendation to
any rto owner is to have youhave to cultivate your.
You have to cultivate yourreputation in exactly the same
way.
Um and I think the only areawhere I'm there, this is
potential I mean, this is quite.
(19:01):
It is quite open in itslanguage.
It's one of the few areas ofthe compliance requirements
that's not black and white.
All of the other components ofthe compliance requirements are
black and white.
So I think that this issomething that we are seeing in
ART play out a lot at the moment, and I think that it's going to
(19:26):
be something where there'sprobably going to be a little
bit of a you know pendulum swingeach way before we kind of come
to a big well, actually, noknowing that it's just going to
swing from one side to the other.
Angela Connell-Richards (19:36):
Yes, we
had a case recently where
someone came to us who hadsubmitted an initial
registration and they were notbacked on so many things.
But fit and proper person wasone of the major areas and I've
already seen quite a bit of withASQA.
(19:57):
They're really coming down on afit and proper person.
Yeah, it's very much a focus.
And this person came to usthrough a referral and I looked
at the audit report and I went,omg.
I was like what had come up wasshe had lied on her fit and
(20:17):
proper person.
There was lots of dodgy stuffthat was happening within the
audit report and she was blamingthe consultant that she had
been working with.
So we so, because this referralcame through one of our
partners, we thought, well,we'll give it a go and we'll go
through further, and we gave heran opportunity.
(20:38):
Because this referral camethrough one of our partners, we
thought, well, we'll give it ago and we'll go through further,
and we gave her an opportunity.
One of the big things was notonly had she lied in her fit and
proper person and didn't statethat she had worked for other
RTOs before, she didn't put thatin there, really, yeah, and
(21:00):
apparently the consultant sheworked with said that she
shouldn't do that, she shouldn'tput that in there, and I'm like
it all comes back to you and itwill come back and bite you.
So you know, ask Cook, it's notthat hard for them to tie you
together into any other auditreport, particularly with ai.
Now they could just run theaudit reports through and just
(21:22):
go have this person ever been inan rto before?
Um, and then the.
Then there was cases where thetrainers and assessors had
falsified documents.
Um and uh, yeah.
So we, we took it on face valueand went okay, yep, maybe you
had a consultant who hadn'tadvised you correctly.
(21:43):
Then we said okay, this is anaction plan, this is what you
need to do.
You need to find some newtrainers to start with.
We're not even going to takeyou on board unless you get some
trainers who hold thequalifications.
Who hold the qualifications?
Well, we got that back thisweek.
And the trainers we once againfound falsified information in
(22:04):
the trainer and assessor filesand it's like, really, guys,
we're not going to work withpeople like that.
You have to be open and honestand when it comes to fit and
proper person, always be openand honest.
Lauren Boon-Hollows (22:18):
They're
going to find out like it's not
that hard statement is likeliterally like 30 pages long.
Now I've got like a 10 pagesupporting statement.
That goes on to it and I'm likehere is a list of every rto
that I have worked with.
Pretty much like half of themyou are either an intent to
(22:40):
cancel or a rejection or like,because that's how a lot of
people come to us, like they'repreparing you know, or like you
know, we've got a lot of RTOslike that.
We've got a lot of RTOs wherethey contact us two years before
registration and they're like,okay, we need to, like, get our
house in order and stuff likethat.
But you know, like I've justfinished doing most of the
(23:00):
annual declarations, most of myRTOs.
In our annual declarations,like I put forward to them, I'm
like you know where it says youknow, have you been compliant to
every single standardthroughout the whole year?
I'm like, no, you haven't.
And they're like you can't saythat, like that's the truth.
I'm like I did a validation foryou three weeks ago.
We identified there was anoncompliance.
(23:21):
We fixed the noncomplianceright and now we're checking the
other units in that samequalification and they're like
we need to ask for that.
I'm like you need to be honest.
I'm like I'm not like.
When I every annual declarationI've pretty much ever done for
RTOs, I've basically been like,no, you have not been compliant
against training and assessmentfor the whole year, because that
(23:43):
is how the validation processworks.
That's you know.
Like it's.
You know you can have complianttools.
You're still not going to havefully compliant assessments
because your trainers are goingto miss a question.
They're going to mark aquestion satisfactory that's not
satisfactory, like this is.
(24:05):
The process that we'reconstantly going through with
rtos is like you just can youjust just be honest, like, just
be honest and be like this isthis is the situation.
Um, the consultant thing, Ithink, is really problematic and
I know that there are, likeseveral consultants in our
industry.
They will do an RTOregistration without any client
involvement.
They write the TAS, they designthe program, they put all of
(24:28):
the policies together and I haveone across.
Yes, exactly, and you know,like I my, I do very, very few
RTO registrations, I think forthe purpose that, like, whenever
anyone calls me up and goes Iwant to start an RTO, my first
response to them is like why,why would you want to do this?
That's terrible.
(24:48):
But then, even when, like theytell me why and I'm like okay,
I'm like, well, I'll give youthe templates for this, this and
this, but then you're going tosit with my staff and you're
going to have to tell me howyou're going to deliver the
program and you're going towrite up the tasks and you're
going to write your trainermatrices and you know, you're
going to sit with us for eighthours and review every single
(25:10):
policy and tell us how you needit contextualized.
And I think when they look atus and like, give them the whole
workload, the vast majority ofpeople are like, okay, that's
cool.
And I'm like, okay, go and getother quotes and see you know,
and then they'll go to somebodyelse and they'll be like we'll
take care of the whole processfor you and you don't need to be
involved.
Angela Connell-Richards (25:27):
But
then you get to audit.
Lauren Boon-Hollows (25:29):
Right, you
get to it.
And then, all of a sudden, theask was asking you questions,
because that's what it knows,that, like you know, this
consultant and that consultantthey know their shit right and
um, so yeah, I had one.
I had one that came across mydesk a couple of weeks ago and
they were like, oh, you know, wewent with this consultant and
(25:52):
I'm reading the report and I'mlike, like it literally says in
there and fit and proper.
Again, that's what they weretargeting.
They were like they're not fitand proper because we asked you
questions about your policiesand you clearly had no freaking
idea what you were doing.
Like you had no understandingof the policy or the procedure
you know, like you don't knowhow to run this out.
Angela Connell-Richards (26:12):
You
know you couldn't answer
questions about the standards,so yeah yeah, I did a podcast on
this recently because this sameclient, um that came to us.
They hired a consultant.
She met with them twice in thewhole initial registration
process, received the policiesand procedures the day before
(26:33):
the audit it.
And for me, like when we workwith our initial registrations,
we call them kickstarts.
We do the same thing.
We actually give them a roadmapof what the work is going to be
involved and we tell them howmuch time per week, like every
(26:54):
week, we're going to be meetingwith you and we're going to go
through these.
We can't do everything for youbecause we're not going to be
asked the questions.
You are going to be asked thequestions and then we have four
PDs that we do per month thatteaches you how to comply with
all of this.
This person had never done anyPD.
We gave her some of our PD ascomplimentary because she
(27:15):
absolutely knew nothing and shewas like was like oh wow, I
actually didn't know all of this.
I didn't know any of this.
So the thing is, you've reallygot to be careful when you're
engaging with a consultant.
An RTO in a box is no good ifyou know nothing about RTOs, if
if you have experience andyou've worked in RTOs and you've
(27:36):
worked in compliance, thenmaybe buy an RTO in a box, but
if you've never worked likenormally our clients, our ideal
client, is an industry expert intheir industry We'll get you
through registration.
We're experts in compliance andwe'll get you through, but
you've got to do the work.
(27:57):
Yeah, exactly yeah.
Lauren Boon-Hollows (27:59):
And I mean
that's exactly it.
Like I mean, if you're notprogressing every week, I mean
even with our policy updates,our clients, they must hate me
at the moment because you know,like every policy that comes out
, we're like, okay, here's thepolicy, here's the changes that
we've made, here's the relevantpart of the standards.
You need to review this.
(28:21):
Then you need to send it backto us and then we're going to
review.
And if you want, to have ameeting.
We're going to have a meetingabout like we've been doing this
now for months.
Like are the quality registersthat we've got with our clients
at the moment because we keep itall on accelerate for each of
them yeah, like the qualityregisters.
In the last between jan and now, you know there's like probably
40 or 50 notes in the registerof like this has been sent out,
(28:44):
this has been approved, this hasbeen done, this has been done.
Yeah, yeah.
Angela Connell-Richards (28:49):
Yeah,
and it's a massive process, like
we've also been working onthrough all of our documents,
and it is a massive process torewrite and then not.
Well, I've taken two ways ofdoing this.
I've done one lot where I'verewritten and another lot where
(29:11):
I've written from scratch sothat I can see what the
difference is between those two.
So when these came out onFriday, I started straight away
rewriting, writing new policiesand procedures against that, and
it is quite a process and Ithink a lot of people don't
realise how much of a process itis.
(29:31):
What are your thoughts on howRTOs existing RTOs are going to
transition over to the newstandards?
Do you think they're goinggoing to transition over to the
new standards?
Do you think they're going tostick their head in the sand?
Lauren Boon-Hollows (29:44):
I think
you're going to have a variety.
I think that I mean we havereceived a lot of calls from
RTOs.
We do a lot of work withAccelerate, so we've been
receiving a lot of referralsfrom Accelerate on just being
able to run some sessions withRTOs on, like, how to go and
update using Accelerate's new,you know, using Accelerate's
(30:06):
mapping right, Go in and map thepolicies and where do we keep
them and how do we structurethem, and everything like that.
So we've been running lots ofthose.
There are a lot of good RTOsout there that are doing the
right thing.
I have seen plenty ofadvertisements of, like buy our
policy set and you'll be fullycompliant.
I know that there was, you know, a new product that was
(30:28):
launched yesterday.
That was, you know, I'm noteven going to say it but like,
it's AI that automates yourentire compliance system and you
don't need to do anything.
Like, okay, I'm just going tosay it.
If you're watching this podcast, if you are told that you can
completely automate complianceusing AI and you don't need to
(30:49):
do anything, please don't wasteyour money, Please don't.
Angela Connell-Richards (30:54):
Because
, once again, you're the one
that's going to be audited, notthe AI bot.
Lauren Boon-Hollows (30:59):
Yeah, and
look, policies are like
assessment tools, like wherepeople will buy them and chuck
them into their system and thenthey're like they can't answer
anything on them.
And when you get audited, youget audited on how you're
applying your policies andprocedures.
That's right.
And half the time you know likethey don't even know what's the
policy and procedures.
Angela Connell-Richards (31:19):
That's
right, and half the time you
know like they don't even knowwhat the policy and procedures.
Lauren Boon-Hollows (31:21):
The policy
is from like 2018, you know?
Do you know what I mean?
Like it's.
Angela Connell-Richards (31:26):
Yeah.
Lauren Boon-Hollows (31:26):
Yeah.
Angela Connell-Richards (31:28):
Yeah.
Lauren Boon-Hollows (31:28):
It's a
process for RTOs where you're
actually reviewing what you do,and does that line up with the
standard?
Angela Connell-Richards (31:33):
Yeah,
yeah, and I definitely use AI to
help me with writing thepolicies and procedures.
But I've trained a bot forthree years now on how to be
compliant and I've got a clonebot of me and it's got all of my
knowledge in there my webinars,my workshops, my documentation.
(31:56):
It's got everything in there.
So I'm going, when I'm creatingstuff, it's me it's not any AI
bot and anybody who's writingpolicies and procedures from the
free chat.
Lauren Boon-Hollows (32:12):
GPT.
Omg, that's a lie, like it willjust outright lie to your face
and it can't, it can'tcross-check, it can only
cross-check so many documentsand stuff like that.
I mean, look, it's a brillianttool, it is absolutely a
brilliant tool and it's it'screated huge time savings, um,
for a lot of people.
But you have to use it in theright way.
(32:34):
It's like the internet, youknow.
Angela Connell-Richards (32:35):
You
have to use it in the right way
yeah, use your intelligence, useyour knowledge, use your skills
.
Um, like, I don't, definitelydo not use the first thing
that's spat out.
Um, I'll refine, refine, refine.
And it's like okay, you'vemissed this bit, you now need to
add this bit in, you need toexpand on this.
(32:55):
Oh, this one, you've got toomuch information.
We don't need that.
Like I see, uh, chat gpt as myintern.
That um knows a lot ofinformation but doesn't know how
I want to put it together,although my bot has learned a
lot now.
It's learned a lot about how mystructure is.
I've even taught it how I wantto structure policies and
(33:18):
procedures.
I love that ChatGPT now hasprojects so I can just go to
that project and work in there.
Yeah, anyway, we could talkabout AI all day, so let's move
on.
Okay, so do you believe thatthe new standards that we have
so the whole suite, haveaddressed the quality concerns
(33:39):
that we've had in the trainingindustry?
Lauren Boon-Hollows (33:43):
I think
that the tools give the
regulator the opportunity toaddress some of the issues that
have been big quality concernsin the industry.
I don't think any legislativeinstrument is ever going to be
able to be the be-all, end-allfix for quality in our industry.
I don't think any legislativeinstrument is ever going to be
able to be the be-all, end-allfix for quality in our industry.
(34:03):
And I mean there's a couple ofreasons for that, and one is
just that with every industrythere's always a cat and mouse
element of like people trying tofind ways around it, and GPT is
a good example of that.
Like there are a lot of people,there are colleges that are
using gpt to mass produceresponses for their students.
(34:25):
Like that's an entire marketthat's opened up now and it has
become a lot harder to be ableto for people that are doing
this professionally.
Like they are professionallyproducing this fraudulent
documentation for the students.
They're getting good at it,right.
So, there's always going to be acat and mouse element, I think,
(34:46):
for all of this sort of stuff.
What I think that the tools dois I think in particular areas,
it provides clarity for theauditors to be able to go and
strike those particular areasNow fit and proper is one of the
areas that they're definitelyattacking.
I think validation under thesenew standards both the with both
reviewing the tools beforehandand the validation after the
(35:08):
fact of the judgments I thinkthat's going to be an area where
there's going to be a lot, Ithink, um online rtos that don't
provide any service to theirstudents and just try to, like
you know, really all they're outthere to do is to get that
student onto that payment plan.
Angela Connell-Richards (35:26):
Yeah,
here's your login, and see you
later.
Lauren Boon-Hollows (35:29):
I think
that you know the fact that they
don't provide any wellbeingsupport, that they don't provide
any support services for thestudents, that they don't
monitor the progress of thestudents in any way, shape or
form.
I think it gives ASQA sometools to be able to address
those particular points, andvery, very clearly I do.
(35:51):
I'll be honest, I do have someconcerns with how ASQA is
operating in the workforcesector at the moment.
I have the biggest amount ofrespect for asper.
I fully agree with them thatprice loss needed to be tackled
because there are some reallybad players in that area and it
does hurt australia's nationalreputation.
I think last year, in the lasttwo years, 90 of the chefs that
(36:14):
have been qualified in australiahave been international and
that's, you know, like that'snot a good thing.
That's not how we should bebuilding chefs in Australia.
Yeah, but I also, yeah, I do,and I mean I think part of it is
just the fact that there's notthere's only so many resources
(36:36):
and, I'll be honest, federal payrates for auditors are really
not that great.
I mean, people like you and Iare not about to go and become
an ASCA auditor because the payjust doesn't support it in any
way, shape or form, and so whatit does support is quite a lot
of people coming into industrythat are like you know, that
just don't have that level ofexperience, um, and that can be
(37:00):
really, really problematic.
So I like I I understand thechallenges that the regulator is
presented with in likeaddressing the myriad of what
they have to do, because youalso kind of want to be an
expert in every area.
Like I'm very fortunate thatover the years I'm very familiar
with cpc, with rii, with, likeI mean, I probably have a really
(37:22):
good breadth of knowledgeacross maybe 20 training
packages.
That being said, I thinkthere's like 100 training
packages and our school kind ofhas to be across all of them.
So you know, how you, how youbuild a team that can do that,
is really really, really, reallychallenging and and maintain
consistency yeah.
(37:43):
So I think that's always goingto be the challenge for the
regulator in combating um, likein combating quality in our
sector.
I like the new annualdeclaration this year I know
this is a bit of an offshoot,but the questions in the annual
declaration.
I like the fact that they'vekind of incorporated the quality
(38:04):
indicator report into theannual declaration.
I like the fact that they'vespecifically asked how many RPLs
you've done as your numbers,and they're going to be able to
cross-check your commencements,your completions and your RPL
with the event list data thatyou've submitted.
So I think that some of thosesorts of things are quite useful
(38:25):
.
And they're also askingexplicitly how many third-party
agreements you had, also askingexplicitly like how many agent,
like how many third partyagreements you had, uh, and
obviously you're going to putthat number in and that number
should be no the same as what'son your website, the same as
what's on ask for net.
So I think that some of thosethings are are good, and I know
(38:46):
that asper is trying to utilizeai and utilize tools to kind of
you know more accuratelypinpoint where the risks are.
They're also very, very muchbedded down with some pretty
major you know.
Like you know, when you look atthe ASPR reports that have come
out and you look at the numberof matters that they've got in
(39:07):
front of them and you look atthe number of matters they're
facing in the ART, you know, Ithink that I can definitely see
at the moment that they've gotin front of them and you look at
the number of matters thatthey're facing in the ART, you
know, I think that I candefinitely see at the moment
that they're at kind of breakingpoint too, and that's always a
really, really stressful timewhen the regulator is stressed.
Angela Connell-Richards (39:24):
For
many of our providers that end
up being stressed, it's going tobe interesting to see how it
all plays out over the next 12months and and more.
Yeah, yeah, okay, so for rto'slistening today, what's the
first thing you think they needto do, or they should do, to
prepare for compliance underthese new standards?
Lauren Boon-Hollows (39:45):
download
them and read them.
Like there's just so many tovote.
Guys look okay, honestly like,if you don't feel you have the
time to actually sit and readthe legal instruments, download
the legal instrument, chuck itinto a paid version of chat gpt
and ask it to give you thehighlights.
Or chuck it into a programthat's going to turn it into a
(40:07):
podcast and listen to it whileyou're cooking or cleaning, like
yeah you know there's so manymechanisms, put it through,
speak ai, it'll produce it'll,it'll read the whole thing out
to you while you're cookingdinner or something like that.
But just just just start tofamiliarize yourself with the
standards.
There's my podcast, there'syour podcast.
(40:29):
Um, you know, like they'll, I'msure that dan hill from spec
training will be putting stuffout um yeah, and phil, phil
bevan's always got something tosay and like just start
listening to what are thechanges in the standards so that
you can familiarize yourselfwith them, and little things
will start to come out.
(40:49):
You'll go, oh well, we don'thave a well-being.
Like we've got no strategy fortackling well-being.
Or like, oh well, we don't doany pre-validation, all of our
validation is after the batch.
Like, oh well, we don'tdocument that you know yeah,
it's super easy to documentstuff.
Guys like jump onto teams.
Add a fireflies or read ai toit and just start talking with
(41:11):
your team about all thecompliance stuff that you're
doing.
Do it once and then take thosenotes and chuck them into your
quality register.
That's it you've got something.
Angela Connell-Richards (41:21):
You've
got something there.
Then the other really importantthing that I I think we need to
add in there is the practiceguides from asqua.
So make sure you're downloadingthe practice guides with all of
the policies that have come outand reviewing that and
identifying where are the gaps,and I think that's perfect.
Listening to podcasts I've gota whole heap of FAQ videos that
(41:43):
I've released on our EduStreamchannel on YouTube and it's just
got little snippets.
They're only less than a minuteand it just gives you an idea.
Oh, are we doing that or do weneed to do that, like it just
prompted?
So it should be just part ofyour ongoing just reviewing and
things like that, and there's somuch out there that you can
access.
What common mistakes do youpredict RTOs will make in
(42:07):
adapting to these changes?
Thinking about previouslegislation, when it's come in
and what people have done?
Lauren Boon-Hollows (42:18):
So I think
the thing that I've learned
throughout the years is to gothrough the standards, pick out
those words that haven't got adefinition and define them right
.
Right, define them reallyclearly.
Um, yeah, so so that you knowwhat it looks like and so that
you know what, how you're goingto stick to it.
(42:42):
Um and again, like there are somany tools out there, the main
thing that rtos do all the timeis they're doing the compliance.
They're doing the tasks thatmeet the compliance.
They're not documenting it.
Angela Connell-Richards (42:57):
They're
not recording it.
Yeah.
Lauren Boon-Hollows (42:59):
Except for
the fact that nowadays we've got
Read AI, we've got Fireflies,we've got transcripts we've got
codes from everything.
Like we've got so many differentthings that we can do.
Yeah, we've got phones.
Look at how you document stuff.
Like, really do look at how youdocument stuff and figure out a
way to make that easier.
And like, if you've got, ifyou've got microsoft zero
(43:25):
accelerate and you're using someof these ai tools, like I
really don't see how the systemis set up so easily.
You know, the biggest changethat we've made with all of our
clients over the last year is weare able to document the
compliance that's happening on adaily and weekly basis with our
clients so much more easilythan we were and than we ever
(43:48):
have been able to in the past.
And thankfully, because we'redoing it, all online now.
Angela Connell-Richards (43:53):
Yeah,
because we're doing it all
online.
It was a bit different when wewere doing it face-to-face, but
we're doing it all online andwe're able to get all of this
data from and you can also usethis data with your industry
consultation.
Definitely, with getting thatfeedback and things like that.
I think one of the commonmistakes that we will see is
(44:14):
people trying to write theirpolicies and procedures using AI
bots and not having it.
I think that's going to be aproblem and not contextualising
it for their RTO and when theygo to audit, that's going to be
an issue.
Same with you know writing yourtraining and assessment
strategies as well.
Like you, you really you can'tjust put something through your
(44:36):
ai and expect it's going to comeout compliant um it like we've
got.
I've got over 30 years ofexperience in the training
sector and it's it's a lot overthose years and and I love
ChatGPT it's my favouriteassistant ever but I would never
, ever take the first thing thatcomes out, even though I've
(44:59):
trained it.
So I think that's going to be acommon mistake that we're going
to see.
I think also, we're going tohave people who are just going
to go.
I'll just wait till I have anaudit.
And I've seen this so manytimes, where they go to audit
and they ring us and go help.
We're going to audit and wedon't know what we're doing.
Lauren Boon-Hollows (45:20):
Late at
that point, buddy, like you're
screwed at that point, yeahdon't wait until you get called
up for an audit.
Angela Connell-Richards (45:26):
You
should be starting now.
You should be as you said justdownload the documents, review
it, put it through ai, get it towrite a podcast for you.
I love that, I think they'regreat ideas.
And talk to talk to your chatgpt on your phone and get it to
just ask it questions and thenget it to answer.
So you, so that you're learningas much as you can.
(45:49):
But but I think, yeah, thosemistakes Don't wait.
Don't wait until you go toaudit or getting called up for
audit or re-registration,because ASQA can audit you at
any given time.
You could be on a focus areathat they want to.
Just because you got throughaudit last year doesn't mean
you're not going to have anotheraudit this year.
So you need to be on top of it.
(46:11):
The other big thing, I thinkbecause it's a big component is
training all of your team on thenew requirements, making sure
that everyone on the teamunderstands the compliance
requirements and I mean records,I mean records is going to be
the biggest part of that.
Lauren Boon-Hollows (46:28):
We're,
we're now it's no longer six
months, so we're going from sixmonths to two years.
We have to keep everything forlonger, um, and so you know, I
know that there are a lot ofrtos out there, probably not
listening to this podcast, but,um, you know that will turn
around and go oh, we only needto keep things for six months.
(46:49):
So therefore, like you know,every year it's like a, you know
, hurrah, hurrah, let's.
You know we're out ofeverything, let's burn it?
Yeah, pretty much.
But yeah, you've got to keepeverything for a minimum of two
years now and if you've gotstate funding contracts, up to
seven years.
Angela Connell-Richards (47:09):
Yeah,
depending on your contract.
Lauren Boon-Hollows (47:14):
Read your
contracts right.
So, yeah, that's um.
You know this is a goodopportunity when we update the
standards to do things like okay, well, what funding contracts
do you have?
When was the last time you went?
You went updated, you know, inline with the wa business rules
or in line with the you know thepqs requirements for queensland
or in line with the Smart andSkilled Operating Guidelines for
New South Wales.
So take this opportunity to gothrough and really review.
(47:38):
There's new IRHR legislationthat's come out in the last
couple of years.
There's been some major WHSupdates across a lot of RTOs.
Most RTOs haven't updated theirpolicies and procedures in a
while.
There's not many aspects of thelegislation that haven't
changed cybersecurity, how youdeal with data breaches, how you
deal with a notifiable databreach incident, all of those
(47:58):
sorts of things.
Yeah, like all of that needs tobe in your policies now.
So you know.
Angela Connell-Richards (48:05):
And the
VET workforce.
Like they're the major thingsI've seen is the VET workforce
requirements more aroundwellbeing, which I think is good
, and also around the trainerand assessor requirements and
maintaining bringing in thoseexperts, I think, is also what's
really good about it as well.
(48:25):
Yeah, okay, so we need to wrapthis up.
It was a very insightfulbreakdown of what we've seen so
far and I love hearing what yourthoughts are on this.
So, before we wrap up, lauren,what's your number one piece of
advice for RTOs looking at thesenew standards and are feeling
(48:45):
overwhelmed?
Lauren Boon-Hollows (48:48):
Just don't
stress out too much.
Download a couple of podcastsand every time you go to cook
meal or go for a drive, play one.
Build your knowledge slowlyover time, over the next couple
of months, and you'll get thereyeah, yeah, great.
Angela Connell-Richards (49:03):
That's
great feedback.
I think that's wonderful.
All right, that's a wrap fortoday.
In our episode where, um, inthis episode, we've covered a
lot when it comes to the newstandards.
In our next episode, we'regoing deeper how the standards
affect trainers and assessorsand the practical steps for RTOs
to implement changes.
(49:24):
So don't miss it.
Hit subscribe and stay ahead ofcompliance changes.
See you, you next time.
Thank you very much, lauren.