ASQA constantly seeks to ensure consistency among its auditors and employs several formal processes to minimise the potential for audit variation, including:
Regulatory moderation workshops: these are focused on moderating issues that may lead to inconsistency in audit outcomes, and on sharing approaches to overcome these issues.
Auditor moderation log: a dynamic record of ASQA’s agreed position on compliance issues. Auditors refer to this log when making compliance recommendations.
Audit report guidance: to ensure consistency in audit report content, auditors refer to a guide, which focuses on reasons for non-compliance, action required, and analysis of additional evidence/response.
Other processes that contribute to audit consistency including an online auditor discussion board.
ASQA also promotes transparency and accountability in its audit program through undertaking quarterly audit surveys each year.
If ASQA identifies non-compliance, you may be given 20 working days to provide evidence that you have rectified that non-compliance.
ASQA will then consider this evidence
If you remain non-compliant with the required standards, ASQA will make a decision about what actions to take next. In making this decision, ASQA will consider your history of compliance and the risks associated with the non-compliance.
Actions might include:
applying a sanction or condition to your registration, and/or
As of 1 July 2018, the audit processes for initial registration and for changes to VET scope within the first two years of registration do not include an opportunity to correct and re-submit additional evidence if non-compliance is identified during the audit process.
In most cases, if you have submitted the applications simultaneously, ASQA will assess compliance with the requirements for both registered training organisation (RTO) and Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS) registration at the same audit. ASQA will audit according to the student-centred audit model and the five stages of the student journey and the relevant standards—Standards for RTOs 2015, the National Code 2018, and/or the ELICOS Standards 2018—for each stage.
When a training provider applies to renew registration, ASQA undertakes a risk assessment of the application. This includes reviewing the provider’s risk profile and a wide range of other sources of data and intelligence.
ASQA’s intelligence sources, which inform regulatory action against RTOs with ‘non-genuine students’, will continue to include a wide range of sources, such as other government agencies and information and complaints from non-student sources.
While the focus of the audit model is the student experience, students are only one of many sources of data that informs ASQA’s audit process.
ASQA regulates providers against the Standards for Registered Training Organisations 2015 (as well as the National Code 2018 and the ELICOS Standards 2018 for some providers) but does not set these legislative requirements.
The Standards for RTOs 2015 are endorsed by The Council of Australian Governments’ (COAG) Industry and Skills Council (CISC).
The Council comprises the Australian, state and territory ministers with responsibility for industry and/or skills within their jurisdiction.
When future CISC reviews of the Standards are undertaken, ASQA will be likely to make submissions based on its regulatory experience, including its experience of developing and administering the student-centred audit approach.
Yes, a consultant may participate in the audit proceedings together with the RTO.
However, an RTO’s executive officers and high managerial agents must be vested with sufficient authority to ensure the RTO complies with the Standards for Registered Training Organisations (RTOs) 2015 (Standards for RTOs) at all times.
An executive officer includes a person who is concerned with or takes part in the management of the RTO.
A high managerial agent means an employee or agent of the organisation with duties of such responsibility that his or her conduct may fairly be assumed to represent the organisation in relation to the business of providing courses.
As part of ensuring an RTO complies with these requirements, executive officers and high managerial agents need to (either individually or jointly) have an in-depth knowledge of the organisation’s operations.
While a consultant is able to participate in the audit process together with the RTO, the primary interactions between an auditor and the RTO should be with those people who have an ongoing involvement in the day-to-day operations of the RTO. This includes discussions with the RTO’s CEO, managerial staff and employees (including contractors).
In the event that an RTO participant, including a consultant or observer brought in by the RTO, acts in an inappropriate manner at the audit, the auditor may choose to remove themselves from the situation if they are feeling threatened, intimidated or otherwise unsafe.
In this instance, the audit will be immediately concluded and a decision as to the audit outcome will be made based on the information available.
ASQA may also consider further action, including reporting the instance to applicable authorities, where warranted.
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