Skills First COVID-19 Updates

In an effort to address the high volume of enquiries submitted by Training Providers, the Department has published a series of documents on SVTS last Friday. The information and guidance published covers a variety of issues and concerns raised by providers due to the COVID-19 outbreak and is broken down into three separate documents:

• Contract Notification 2020-05: Government response to novel coronavirus (COVID-19)
• Skills First and Covid-19 – Questions and Answers
• Fact Sheet: Covid 19 – Disrupted Training and Reapportioning

Contract Notification 2020-05: Government response to novel coronavirus (COVID-19)

This Contract Notification includes a temporary Contract variation in relation to the “Notices” requirements. As per clause 15.1 of the Contract, all Notices issued by either the Training Provider or the Department, must be in writing, signed by or on behalf of the party giving it and hand delivered or sent by prepaid priority post. Until further notification, Training Providers must now submit these Notices through the “Enquiry” function on SVTS while the Department will issue all Notices by publishing Contract Notifications in the ‘Memos’ section of SVTS or via raising an enquiry directly with an individual training provider through the “Enquiry” function of SVTS. Any Notices sent by Training Providers via post prior to 10th April, must be re-submitted via SVTS to ensure they are received.

The Notification also includes advice about flexibility in relation to some compliance requirements. The Department has acknowledged that the current circumstances have greatly impacted training providers’ capacity to operate in a business-as-usual manner. Therefore, until further notification, flexibility can be applied to some contractual requirements. There are many instances where the Department has accepted the advice of the National Regulator on how things should be managed in the current circumstances.

More specifically, flexibility can be applied to the following contractual obligations:

• Skills First Internal Audit: Deadline for completion is extended to 30th September.
• Online Service Standards: Training providers who are now adopting online training and assessment must focus on providing practical information to their students rather than publishing this document in a prominent place on their website.
• Workplace-based Assessment: If the training provider is unable to visit the workplace in person, then assessors can remotely observe the learners via video recordings or video conferencing applications (Skype, Zoom etc.)
• PD for Skills First Teachers delivering online training/assessment: Training providers should be prioritising ensuring that trainers/assessors are well equipped to deliver online training, more comprehensive professional development can be conducted later.
• Pre- and post-testing of Foundation Skills: Training providers are not required to collect and submit the data required in relation to students undertaking Foundation Skills courses.
• Evidence of concession entitlement: Training providers must make all reasonable efforts to sight and retain evidence of concession as prescribed by the Contract. If this is not possible, they will be allowed to sight electronic copies of concession cards such as a scan or image sent by email. In this scenario, training providers must complete and sign a declaration and attach it to the student file together with the electronic copy of the card. This declaration must include the name of the authorised delegate who sighted the card and the date that the electronic copy was sighted.
• Evidence of eligibility: Training providers must make all reasonable efforts to sight and retain evidence of eligibility as prescribed by the Contract. If this is not possible, they will be allowed to sight and retain uncertified copies of identification documents such as a scan or image sent by email.
• Workplace visits and other face-to-face requirements for Apprenticeship/Traineeship Delivery: Workplace visits and other face-to-face contact between the training provider, employer and apprentice/trainee can now be conducted by alternative means available such as via phone or through teleconferencing or video recording. For units of competency requiring training and assessment to take place in the workplace, training providers will need to defer training and assessment until it is possible to attend the workplace.

Skills First and COVID-19 – Questions and Answers

This document has summarised the answers to technical questions most frequently asked by Training Providers via SVTS under the COVID-19 enquiry category. It covers a range of topics associated with the Contract such as statistical reporting, withdrawals, evidence of participation, online delivery, and training plans.

This is a brief summary of the most important points of this document:

• Reporting Training that has been interrupted but it is believed to resume in the future
  • Report final outcomes that apply to completed units (e.g. codes 20, 30)
  • Report outcomes 70 (continuing) or 79 (waiting employer sign off) for units that are still in progress, including units where supervised training and assessment has finished but required practical placement is yet to be completed
  • Extend unit end dates to either the best estimate of when the training will end or to end of the next month at which point you will need to extend it again
  • Report the Program Status Identifier value as 42 Withdrawn (Deferred)

• Reporting Training that has been discontinued
  • This should be reported in line with the Fact Sheets for Withdrawn Subject Enrolments and Withdrawn Program Enrolments. Please note that an updated version of both documents (v.2.0) was published on SVTS on 2nd April

• Reporting Training where all supervised components have been completed but a mandatory practical placement is not completed
  • Report as usual but change the Program Status Identifier value to 42 Withdrawn (Deferred)

• Individuals will still be entitled to Skills First funding when they recommence their studies, provided that they are unable to continue their current studies due to one of the following reasons:
  • RTO no longer offers the qualification
  • The qualification is being delivered in a different way that isn’t suitable to their way of learning (e.g. fully or partially online)
  • They cannot complete a requirement to finish their studies (e.g. practical placement)
  • They have withdrawn due to changes to personal circumstances as a result of COVID-19

• Changing Delivery Mode to Online
  • The Delivery Mode can be changed to Online (“External Delivery” in NAT00120)
  • RTOs must ensure that they have relevant infrastructure in place and suitably trained staff available
  • RTO must ensure that all continuing and new students have digital literacy and access to technology

• Updating the TAS when changing the Delivery Mode
  • In the current situation, any records of TAS variations and adaptations can be captured across multiple documents
  • Communicate with your regulator (ASQA or VRQA) if you are unsure whether your changes are consistent with the Training Package requirements

• Updating Training Plans when changing the Delivery Mode
  • Send the student an email or online message about any changes and keep a record of the communication
  • For apprenticeships/traineeships, changes to the Training Plan must be mutually agreed and endorsed by all parties. Informal endorsement will temporarily be acceptable (e.g. email exchange or file note recording the outcome of a phone call)

• Updating Program Delivery Plans when changing the Delivery Mode
  • This is not required

• Reporting online or distance learning
  • Training Delivery Location should be changed to your coordinating office
  • Delivery Mode Identifier must be updated to contain Y as the middle character (select “External Delivery in your SMS)
  • Predominant Delivery Mode must be updated to “E” (External Delivery) if online becomes the main method for training and assessment across the unit of competency

• Evidence of Participation for Online or Distance Learning
  • To show attendance in an online class, you will need to have evidence that each student logged into your LMS at the time the class was conducted and be able to show which units were delivered
  • Attendance of on online class must be endorsed by the Skills First Teacher. This could be done by showing evidence that the Skills First Teacher has to log into a secure platform using a unique username and password and having them complete a “tick box” process that shows they have confirmed who attended the class and they have endorsed the information (consent and reliability)
  • Examples of EOP demonstrating “log-in and engagement with learning and/or assessment activity” may include a record of the student participating in an online discussion forum, a record of the student completing a self-paced activity within an LMS, emails or other communication between the student and the Skills First Teacher
  • Examples of EOP demonstrating “records that indicate that the student has commenced working on the learning materials they have received and have engaged with learning and/or assessment activity” may include Skills First Teacher notes demonstrating a two-way communication and interaction via phone or email confirming that the student is working on the learning materials
  • Skills First Teacher’s attempts to call a student and leaving a voicemail or login records indicating the student received training material alone is not sufficient evidence

• Programs that cannot be delivered 100% online
  • Please refer to the 2020 Online Delivery Restriction List for courses that cannot be delivered wholly online
  • For new students enrolling in a course on the Online Delivery Restriction list, the Department suggests that you commence training in an online delivery mode now and deliver the face-to-face components at a later date

• Contract-related resources about Online Delivery
  • 2020 Online Service Standards
  • Fact Sheet: Quality in Online Learning
  • 2020 Online Delivery Restriction List

• Electronic Signatures
  • Please refer to the recently published “Fact Sheet: Using Electronic Signatures” in the documents section of SVTS or take a look at our article on this
  • Under the COVID-19 circumstances, if your organisation doesn’t have appropriate processes in place for collecting electronic signatures (e.g. electronic signature software), then you can implement informal processes such as asking your students to complete a form and return it to you via email. If such an action takes place, you must ensure that the student is the person undertaking the action (e.g. email address matches to email that you have on the student’s file) and the student also indicates their agreement or endorsement, by including a standard text for them to acknowledge in a return email

Fact Sheet: COVID-19 – Disrupted Training and Reapportioning

As many training providers are currently struggling to maintain a positive monthly cash flow due to disruptions or delays to their training delivery, the Department has developed an alternative reporting mechanism which allows to temporarily suspend units of competency from the SVTS reapportioning payment logic. If your organisation opts-in to use this mechanism, any extensions to the activity end dates of “in progress” (code 50 or 70 or 79) units of competency won’t trigger payments to be recalculated over the updated delivery duration.

To achieve this, the subject enrolment must be reported with the Purchasing Contract Schedule Identifier code of “C19”. The process is similar to excluding subject enrolments from either claim creation or claim confirmation which was brought into place in October last year. The newly created Purchasing Contract Schedule Identifier may be reported against units of competency where the activity end date has been extended in the future due to training being temporarily suspended or external verification of training is unavailable or training is continuing but with significant delays.

When reporting subject end dates in this way, no reversals of funds will occur due to reapportioning and future payments will occur as per the end date in the last processed upload to SVTS, before reporting with the code “C19”. Reporting (as outlined below) can start now, and adjustments to payments will occur from the early May payment processing cycle.

Example

By 1 March 2020, a subject was reported with 150 scheduled hours with Activity Start Date 15/02/20 and Activity End Date 15/06/20:

By 1 May 2020, the same subject was reported with 150 scheduled hours, however the Activity End Date has been extended to 15/09/2019. Prior to the May payment being made, claims processor will calculate the following:

If the training provider chooses to report the Purchasing Contract Schedule Identifier code as “C19”, then the payment calculation will look like this:

Please note that this is a temporary arrangement and once things return to a sense of normality, all claims that have been treated in this way will be aligned with the extended duration of the claim. You will need to contact your SMS vendor to find out whether the new Purchasing Contract Schedule Identifier will be automatically created within your SMS or it needs to be manually created by your admin personnel.

Training Providers should take advantage of as many flexible arrangements as possible to ensure ongoing operations and financial viability. The fact that the Department acknowledges the current operational barriers that many organisations have to overcome and attempts to reduce the compliance burden is definitely encouraging. Our industry is sailing into uncharted waters at the moment and nobody can predict how long this will continue for. Keep in mind that any arrangements that are currently described as temporary may end up becoming permanent procedures. Eventually, COVID-19 may trigger a transformative change in vocational education and it would be wise to consider the sustainability of any new business processes that your organisation will develop and implement due to the current circumstances.