Taking into account RTO’s need for certainty, the Department has offered a Skills First contract of 2-years duration. The longer-duration contract gives providers the certainty required to invest in infrastructure and resources and to respond more strategically to jobs and training needs. At the same time, the new VET Funding Contract came with commencement allocations which re-affirmed the commitment of at least 70% of the funding going directly to Victorian TAFEs and dual-sector universities. In this blog, we focus on the most important updates in the 2024-25 Victorian VET Funding Contract, especially with those affecting operational and training aspects of training organisations with a Skills First contract.
Physical Presence in Victoria
It has always been a requirement for students to be physically present in the State of Victoria while undertaking supervised training and assessment. In the current contract, the requirement has been expanded to include students who live close to the Victorian border, either in New South Wales or South Australia. Now students who reside in one of the postcodes identified in the table below, can do online or workplace-based training from within those postcodes as well as crossing the border into Victoria for training:
NSW | SA |
---|---|
2546 | 5262, 5263 |
2548 – 2551 | 5267 – 5272 |
2625 – 2633 | 5277 – 5279 |
2640 – 2648 | 5290, 5291 |
2650, 2651, 2653, 2655, 2656 | 5302 – 5304 |
2658 – 2660 | 5311, 5333, 5340 |
2700, 2707 | 5342 – 5345 |
2710 – 2717 | |
2720 | |
2730 – 2739 |
For instance, a student who resides in Tumut (NSW, 2720) is now able to complete the online portion of their training and assessment without having to cross the border into Victoria. Furthermore, they can complete a workplace-based assessment in a workplace setting within Tumut or another one of the postcodes listed above.
It is a common misconception among training providers that they must sight and retain evidence of the student’s address (e.g. drivers license, electricity bills etc.). Providers do not have to sight and retain any evidence in relation to the “physical presence” eligibility requirement. They can rely on the postcode a student provides on their enrolment form as their home address to check whether the student is in Victoria or in one of the identified border regions.
Evidence of Eligibility
The Evidence of Eligibility and Student Declaration form has been simplified to make it easier for students to understand and complete. The provider’s declaration page has been simplified too and changed into a checklist-style format.
Some training providers may find it difficult to collect the information they need to assess eligibility via the use of the new form since several of the old questions (e.g. number of enrolments in qualification and/or qualifications, education history etc.) have been removed. For example, a training provider that delivers Foundation Skills Programs won’t be able to find out whether a student holds a Diploma or a higher qualification or not, if they use the form designed by the Department. They would have to collect this information either from the student’s answer to the mandatory enrolment question about their education history or as part of the pre-training review.
However, providers are allowed to modify this form and include additional questions that will help them in the process of assessing their student’s eligibility for Skills First training. As long as the information collected is at least the same information collected by the Department’s form, providers do not have to use the form the Department provides.
The Department has also included some new obligations in the contract, to help training providers to protect students’ personal information from potential data breach and identity theft. As a result, if for privacy reasons, a student doesn’t want you to retain their evidence of eligibility (e.g. green Medicare Card, Australian Passport etc.), you must instead retain a written declaration and attach it to the student’s file. This declaration must state that you sighted the evidence, and include the name of the authorised delegate, the date they sighted the evidence, the student’s name, and the type of evidence sighted.
Fee Concession and Fee Waivers
Concession entitlements must be checked as part of the enrolment process, including situations where a payment plan is offered, and a separate invoice is issued when an instalment is due to be paid.
Under the new contract, this also applies to situations where fees are not charged at once but on a periodic basis (e.g. each term or semester or every time a new unit of competency commences). Training providers do not need to be re-checked concession entitlements in this case.
If you checked the student’s concession as part of enrolment and it was current and valid at the time, it applies to all tuition fees for the program, regardless of whether the concession card will expire before commencement of training or before the student completes their training. If you do not charge all fees for an enrolment in one instance at the start of the program, you must inform students that if they obtain a Concession Card after the commencement of training they may present it to you, in which case you must charge the concession fee rate for any remaining fees not yet charged.
Furthermore, from 1st January 2024 the Skills First Aboriginal Access fee waiver has replaced the Indigenous Completions Initiative concession. Training providers must not charge a tuition fee to Skills First students who self-identify as being Aboriginal or Torres Strait Islander descent. Like the previous Indigenous Completions Initiative concession, training providers must retain a copy of the enrolment form on which the student self-identified as indigenous as evidence of their entitlement.
For students who commence their program in 2024, you must apply the new fee waiver. For continuing students where you didn’t charge all fees for an enrolment in a program in one instance, you must apply the new fee waiver for subjects that commence on or after 1st January 2024.
As a result of the new contractual obligations relating to student personal information protection, training providers must not retain copies of a student’s evidence of concession or the concession holder’s Centrelink Customer Reference Number (CRN) for the purpose of checking concession entitlement for Skills First. This is because a CRN can’t be changed if it is subject to a security breach, unlike other forms of identity evidence where a new card or document number can be issued.
This means that if your organisation’s business process is to sight the original concession card for the purpose of checking students’ concession entitlement, you are no longer required and allowed to retain a copy of it. You must instead keep a written declaration attached to the student’s file stating that you’ve sighted the evidence of concession. This must include the name of the authorised delegate, the date they sighted the evidence, the concession holder’s name, and the card type.
If you are verifying concession entitlements through the Document Verification Service or the Centrelink Confirmation eServices, continue to keep a transaction record in the same way you do now. These transaction records do not include the concession holder’s CRN anyway.
The Department has also clarified that if you are using the Centreline Confirmation eServices to check concession entitlements, the extract that you retain does not need to include the concession holder’s name. This is because the eServices extract only indicates a positive match for the name you enter as part of the confirmation. They now only require that the extract shows the card type and the date the extract was made.
Free TAFE
Any student eligible for Skills First can get a tuition fee waiver for a Free TAFE program at a TAFE or dual sector university. Students can get fee waivers for Free TAFE priority courses and Free TAFE short courses.
Free TAFE priority courses are AQF qualifications on the Free TAFE for Priority Courses list. The general rule is that a student can only get a fee waiver for one Free TAFE priority course in their lifetime. However, there are some exceptions to this rule. An individual may receive an additional Fee Waiver if:
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- the only previous Free TAFE Fee Waiver they received was for a commencement under the JobTrainer initiative or
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- they previously completed a program (whether government-subsidised, including under Free TAFE, or fee for service) that is part of a Free TAFE pathway identified on the Funded Programs Report, and are commencing another Free TAFE program in the same pathway.
These exceptions have been in place since last year. From 1st January 2024 onwards, the exception also includes students who would like to get a fee waiver to do the Certificate IV in Training and Assessment. Students who have previously completed a Free TAFE priority course, can get an additional Free TAFE fee waiver to do the Certificate IV in Training and Assessment. This is to encourage industry-qualified people to consider a career in VET training.
Evidence of Participation
There have been changes to the requirements relating to Evidence of Participation (EOP) which apply to subjects commencing in 2024. The previous requirements will continue to apply for subjects that commenced before 2024 and are continuing in 2024.
The main changes relate to subjects of more than 30 days and to withdrawn subjects.
For subjects with a delivery period which is longer than 30 days, you now don’t need to keep your second item of EOP in the 30 days before the Activity End Date. Instead, your second item must be evidence of assessment, showing the student completed their assessment task or tasks for the subject. And your first item of EOP can be any of the accepted types, except for evidence of assessment. The evidence of assessment item must show the student has completed their assessment for the subject − not just an interim assessment.
For withdrawn subjects, you now only need to keep one item of EOP. You can use any of the accepted items of EOP, except evidence of assessment as it won’t apply for a subject the student didn’t finish the training.
For RPL subjects we’ve clarified that you need to keep one item of EOP, regardless of the reported length of the subject, and it must be the assessment tool used for any skills recognition assessment.
If you’re a TAFE or Dual Sector training provider delivering Literacy and Numeracy Support Units, you must keep one item of EOP per subject. For example, if you deliver 3 subjects within the student’s 100-hour Literacy and Numeracy Support allowance, you’ll need to keep one item for each of the 3 subjects. It doesn’t matter whether the individual subjects are 30 days or less, or more than 30 days. You can use any of the accepted EOP types.
Data Reporting
The “Commencing Program Cohort Identifier” has been a mandatory element for reporting in the NAT00130 file since 1st January 2023. This element identifies students belonging to a specific cohort/s and may or may not be independent of the Funding Source Identifier.
This question now forms part of the standard enrolment form and should contain a link or a more detailed description of the value. Students may choose to include in their answer up to three different values.
If your organisation’s enrolment process is paper-based or you are conducting online enrolment using tools designed internally, then you must update your enrolment form in line with Appendix 1 of the Victorian VET Student Statistical Collection Guidelines – 2024 v1.0. If your organisation is using an online enrolment platform provided by your SMS vendor, then you must check with them to ensure that they have updated their product to address this requirement.
Training plans for non-apprentice/trainee students
Training providers no longer have to include the scheduled hours for each subject in the training plan for non-apprentice/trainee students. Clause 6.11, Schedule 1 has been updated accordingly. However, this change doesn’t apply though to students who are apprentices or trainees. Please note that the training plan requirements are different for apprenticeship/traineeship enrolments and are outlined in Clause 6.18, Schedule 1 of the VET Funding Contract.
Online Training and Assessment
The definition of “Online Training and Assessment” has been removed from the contract, as it’s no longer needed. The Department has the same expectations about student engagement and quality training delivery regardless of the delivery mode.
As a result, for online training and assessment, training providers no longer have to:
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- publish online service standards on their website
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- include extra information in their Training and Assessment Strategies for programs that include online delivery, such as the method for engaging students and monitoring their progress and validating online assessment tools.
Workplace Assessment
Clause 7.3, Schedule 1 used to stipulate that “where the Training Package or course curriculum requires that a subject be assessed in the workplace, the Training Provider must visit the Skills First Student’s workplace in person to carry out that assessment.“
The Department has now recognised that, provided the principles of assessment and rules of evidence can be met, there may be multiple options for workplace assessment such as simulations and using evidence collected by third parties. Hence, the above clause has been changed as follows: “You must conduct assessment in programs on the Funded Scope in compliance with Regulatory Standards and the assessment requirements of the relevant Training Package or accredited course.“
Literacy and Numeracy Support
From 2024, only TAFE and Dual Sector Universities can access the Literacy and Numeracy Support program. This is because the program was not being used by non-TAFE training providers. The Standard VET Funding Contract no longer refers to this program.
Records Management
The obligation of not disposing of any records until three years after the Skills First Student to whom the records relate has completed or withdrawn from the relevant program, they are enrolled in has not changed. However, it is expected that training providers dispose of records with personal information as soon as practicable.
For record retention requirements of past contracts, please refer to our relevant article: https://www.rtologic.com.au/skills-first-spring-cleaning/
Your organisation must have a process for promptly disposing of records that include personal information when you no longer have a reason to keep them including once the requirement to keep them under the contract or any other regulation or law ceases.