7 Things to Consider When Preparing for ASQA Registration Renewal

Preparing for your registration renewal can be a scary prospect, particularly because it is such a long time between renewals, and you haven’t necessarily had the regular feedback from the regulator that you get with say, a State Funding contract.  In this article, we highlight the critical considerations you should make in preparation for your renewal process.

Consideration #1 – Timing

First thing is first, make sure you are aware of your obligation to submit your intent to re-register more than 90 days prior to the expiry of your registration.  If you don’t know this date, you should.  It can be found on training.gov.au under the Registration tab and you should incorporate this obligation into your compliance schedule.  Once you have this date, work backwards from here.  You should aim to be 100% confident and prepared before you submit your notification and prior to this, you may need anywhere from one month to twelve months to review and refine your business policies and procedures, depending on your capacity and capabilities. 

Consideration #2 – Complacency

Fortunately (or unfortunately), a long time may have passed since your last regulatory audit.  In some cases, your last audit may have even been under the old SNR framework.  Regardless, a long time has passed and without interaction from the regulator, your organisation may have become complacent.  It’s easy to get caught up in the daily operational grind of running an RTO and we rarely take the time to step back from the operations and look at the fundamental compliance framework that supports our organisation.  If this is the case, now may be the perfect time to undertake a review of your systems and processes through the completion of an internal audit or by engaging an external consultancy firm to understand how you are positioned with respect to the standards.

Consideration #3 – Your public profile

One of the first things that could happen from ASQA’s end is a desktop review of your publicly available information.  Before you even consider notifying ASQA of your intent to renew registration, you should ensure that all public information pertaining to your organisation meets the regulatory framework.  This includes but is not limited to:

• Your TOID is on your website and all marketing materials, course brochures, etc.
• Complaints and Appeals policies are available
• Student Handbook is available
• You are only advertising accredited programs on your scope of registration
• Third party arrangements are made clear on your publicly available information
• Course codes and titles (or unit/module code and title) are listed on web pages, brochures and other marketing materials

Most of the above should be easily located on your website.

Consideration #4 – Outdated Policies and Procedures

Are your operations centered around outdated or redundant policies and procedures?  Just because it passed audit last time around, doesn’t mean it will work this time.  The VET sector is a rapidly evolving beast and with the excessive media attention in recent years, the regulator’s audit approach and expectations have changed considerably in the last 5 years.  We recommend a complete review of your policies, procedures, registers, templates, etc. and some questions you should ask yourself include:

• Do the policy docs reference and align to the current Standards for RTOs? (Found Here)
• Do the policy docs reference redundant positions or people?
• Do your procedures align to those mentioned in your policies or have they changed?
• Can you demonstrate that what you do on a daily basis is an accurate reflection of your existing policies and procedures?

We recommend an annual review of all policies and pro forma to ensure what you say you do, is what you do.

Consideration #5 – Up to date Registers and Schedules

Another key component of your operations is your registers and compliance schedules.  These can include:

• Continuous improvement register
• Complaints and Appeals register
• Validation schedule
• Regulatory compliance requirements (including renewal, fees, updates to legislation, etc.)
• Staff compliance meetings (including agenda and minutes)
• Student feedback schedules (including evidence where feedback is discussed)
• Industry engagement and TAS reviews

Consideration #6 – Trainer/Assessor Files

The quality and availability of trainers/assessors will be heavily scrutinised at audit and as such, we recommend that you ensure your trainer files include the following at an absolute minimum:

• Current resume (last 12 months)
• TAE evidence including certificate and transcript
• Evidence that the TAE qualification was verified by your organisation
• Vocational competencies relevant to the programs being delivered/assessed
• A competency matrix that identifies the trainer’s vocational and industry experience that is relevant to the training products that they delivery and/or assess (mapped to an element level, with references to recent job titles, organisations and accountability – make sure these references are supported by the resume)
• A professional development log (evidence of the last 12 months), including proposed future PD activities (next 6 months)
• National Police Check
• Working with Children (if offering programs to learners under the 18 years of age)

Consideration #7 – Financial Viability

You may be asked to submit a completed financial viability risk assessment spreadsheet and even your strategic plan.  This is not something to take lightly and should be given your absolute attention and priority.  Time and time again, we see organisations fail audits based on their submission of inaccurate, ambitious or incomplete financial viability requirements.  In most cases, the RTO will engage their accountant to complete the spreadsheet but you must consider the following:

• Your accountant may not understand the regulatory framework and will make assumptions that ASQA understands your business
• Include as many explanatory notes to ensure ASQA auditors understand the reasoning behind your figures
• Be realistic – you don’t have to enrol 1000 learners to be financially viable
• Be aware that ASQA will often fail you on clause 1.3 if your spreadsheet does not accurately forecast trainer and facility expenses (this is a major focus under their current regulatory strategy