Skills First Spring Cleaning

The Victorian VET Funding Contract has required Training Providers to create and retain sufficient records relating to the services provided to eligible individuals, to allow the Department to determine compliance with the Contract. These records can be in either electronic or hardcopy format and must include information about the following elements:

• Evidence of Pre-Training Review (including literacy and numeracy assessment)
• Evidence of Eligibility
• Evidence of Concession/Fee Waiver
• Evidence of Enrolment
• Statement of Fees
• Invoices/Payments/Refunds
• Training Plan
• Evidence of Participation

The current VET Funding Contract stipulates that “Training Providers must retain (and not dispose of) any records until three years after the Skills First student to whom the records relate has completed or withdrawn from the relevant program they are enrolled in“. This applies to all different types of records and to every eligible individual who commenced training on or after 1st January 2021. However, this has not always been the case, as the Department has modified the retention requirements from time to time. Older versions of the Contract reference different retention periods or even stipulate that some types of records must be retained for a longer period than others.

We have summarised the record retention requirements prescribed in every Victorian VET Funding Contract since 2009 in the following table:

As you can see, the retention requirements vary, depending on the commencement date of the eligible individual and the type of records that must be retained by the Training Provider.

The current and the 2018-19 Contracts do not distinguish between different record types, and stipulate that all records relating to Training Services must be retained for at least three years after the eligible individual has completed or withdrawn from their program enrolment.

The 2017 Contract references the exact same retention period, although the starting point of this period is the end of the Term rather than the program completion or withdrawal. The Term of the 2017 VET Funding Contract begins on 01/01/2017 and continues until the earlier of:

• all Eligible Individuals in respect of whom the Training Services are provided by the Training Provider and in respect of whom the Funds are provided by the Department have completed or withdrawn from the relevant training course or qualification in which they are enrolled or
• such time as there has been no training activity reported against this VET Funding Contract for any continuous period of 12 months after 15 January 2018, unless no later than 30 days before the expiry of the 12 month period, the RTO notifies the Department that one or more relevant Eligible Individuals remain enrolled in a relevant training course or qualification.

The VET Funding Contracts from 2012 to 2016 set different retention requirements for different types of records. Records related to the enrolment process must be retained for at least seven years, whilst records related to training plans must be retained for at least two years, from the point of program completion or withdrawal. Evidence of Participation must be retained for at least two years; however, the disposal date will be different for each unit of competency since the starting point of the retention period is the unit of competency Activity End Date rather than the program completion or withdrawal date.

All records, including Evidence of Participation, associated with enrolments funded by the 2011, 2010 and 2009 Service Agreements must be retained for at least seven years after completion.

Before you commence any spring cleaning activities and dispose of paperwork that has occupied your filing cabinets for years, we suggest that you read through the following examples to ensure that the disposal dates are calculated correctly.

Example 1

George commenced Skills First training in July 2019 and completed it on 10th February 2021. His enrolment was funded by the 2018-19 VET Funding Contract; therefore, the Training Provider must retain all training records relating to him for at least three years from his completion date. The Training Provider may dispose of George’s records after 10th February 2024.

Example 2

Anika commenced Skills First training in February 2017 and completed it on 20th March 2018. Her enrolment was funded by the 2017 VET Funding Contract; therefore, the Training Provider must retain all training records relating to her for at least three years from the end of the Term. To determine the end of Term, the Training Provider must consult with Clause 2.1 of the 2017 VET Funding Contract. The end of the Term is the earlier of:

• All Training Provider’s students funded by the 2017 VET Funding Contract have completed or withdrawn from the relevant training course or qualification in which they are enrolled
• Such time as there has been no training activity reported against the 2017 VET Funding Contract for any continuous period of 12 months after 15 January 2018.

Example 3

Sue commenced Skills First training in April 2016 and completed it on 15th November 2017. Her enrolment was funded by the 2014-16 VET Funding Contract; therefore, the Training Provider must retain all training records relating to her enrolment (Evidence of Eligibility, Evidence of Concession, Pre-Training Review and Enrolment Forms etc.) for at least seven years from her completion date, and records relating to her Training Plan for at least two years from her completion. The Training Provider may dispose of Sue’s enrolment documentation after 15th November 2024 and Sue’s Training Plan after 15th November 2019. Sue’s Evidence of Participation must be retained for at least two years after Sue has completed the unit of competency in question. This means that the Training Provider must take the Activity End Date for each unit of competency into account when determining the disposal dates. For instance, if Sue completed one or more units of competency on 20th August 2016, then the corresponding Evidence of Participation may be disposed after 20th August 2018.