Skills First Compliance 2019- 5 Things Skills First Providers Need to Know

In this article, we take a look at our auditing experiences across 2018 and 2019 with Skills First contracted RTOs and give you our top 5 traps that Skills First funded RTOs are falling into.

Trap #1 – Skills First Eligibility Forms

It doesn’t matter how many times your staff read the Skills First contract, participate in professional development sessions, conduct RTO delegate training, etc., someone always misses a tick box or signature field on the Skills First eligibility form. The problem with this is, the Department of Education is no longer accepting this “human error” excuse. In fact, RTOs are being made to pay back the entirety of funds for any student whose eligibility form isn’t 100%. So with this is mind, DON’T MESS IT UP!

If you don’t have a process in place, make sure you get a staff member other than the person conducting the enrolment session to check each eligibility form BEFORE it makes it to data entry. For small RTOs who don’t have a lot of staff, you can still review your own work – look at the form in isolation of other documentation. If you miss ANYTHING on that form, you could potentially end up training that funded student for free.

Trap #2 – 2nd Type of Evidence of Participation

When a student withdraws and they haven’t handed any assessments in, you’re faced with the dilemma of only having one point of evidence of participation. MANY RTOs have failed this at audit for their withdrawn students. Providing attendance records for each month that the unit of competency is open for simply isn’t enough. Clause 11.5 of the Skills First contract outlines the acceptable types of evidence of participation for you so you may want to revisit your EOP collection process. Look at teacher notes or diaries and collecting non-assessed classroom activities like quizzes, as further evidence. This will protect you from Clause 11 should the student disappear from the face of the earth.

Trap #3 – Skills First Tuition Fees

Time and time again, RTOs are doing all of the hard work to calculate and report the tuition fees correctly, only to generate a student invoice incorrectly. If you’re using an excel based process for generating student invoices, make sure your formulas are checked regularly and ensure that excel rounding is not affecting the end result – we have had several clients invoice incorrectly because a cell’s formula has been changed or excel has rounded the cents up. Even a 1 cent change to the hourly tuition fee rate can have massive implications on the data you report. When the auditors come in, they’re more than likely going to be young finance or business graduates looking to prove their worth and they’ll pick up on every little detail.

Trap #4 – Skills First Training Plans

How does one get the training plan wrong? The requirements are written in the contract, there are that many templates floating around the industry, even student management systems have templates built in. But still, we get it wrong. I don’t blame you; the contract can be hard to interpret and until something gets tested at audit, you never really know if its strong enough. 

Training plan compliance is a must. Common mistakes include:

• Not displaying the PSTACD
• Mixing the terminology “Nominal Hours” and “Scheduled Hours”, especially if you reduce the hours as part of RCC or similar (technically, the contract calls for scheduled hours only but to be safe, put in a nominal hours column)
• Inaccurate assessment methods documented against each unit 
• Not providing an area on the template to document student support mechanisms (as generated from your Pre Training Review)
• Fields required for Apprenticeships/Traineeships

This should be an easy one to get right – so do a little check of your template against Clause 7 of the contract.

Trap #5 – Becoming an Insular RTO

This may sound like a convenient plug for some consultancy services, but across the industry, I can categorically say, the RTOs that don’t network and don’t seek external advice are the ones suffering most at audit. EVERYONE seems to be an experienced consultant these days – that’s what happens when the private sector shrinks – people go out on their own, but finding an experienced advisor can open up possibilities you never thought existed. If you simply cannot afford it, start utilising the free resources out there such as industry blogs like this one, free PD sessions run by the VET Development Centre, information sessions run by the Department of Education and discussion forums like LinkedIn groups.