Recently ASQA has announced a series of changes to its audit model and audit processes. Are you Audit Ready?
Don’t put your head in the sand!
For your convenience we have summarised the changes to ASQAs Audit Model for you.
- ASQA will now publish its regulatory decisions
From 1 July 2016 ASQA will publish information on its websites about decisions on RTOs shortly after decisions are made. If you fail at audit, this will now be published and publicly available.
Click here to view the list of ASQA regulatory decisions
- ASQA has changed its decision making processes
From 1 August 2016, if ASQA finds ‘highly concerning’ non-compliances at audit, the Commissioners of ASQA can now make a joint decision on the outcome of an audit and any sanctions, penalties or fines that may be applied. It is important to understand that if the ASQA Commissioners make a joint decision, you cannot appeal and respond directly to ASQA anymore. This decision can only be reviewed by an external authority (typically the Administrative Appeals Tribunal (AAT) ). In this instance, the RTO cannot apply for an internal ASQA reconsideration of the decision.This is a real game changer. If your RTO does not get it right at audit, ASQA can essentially throw the book at you on the spot and you will have less opportunity to rectify your non-compliances directly with the regulator. If your audit is significantly non-compliant you risk needing to appeal ASQA’s decision directly with the AAT.
- ASQA has changed its audit process
When ASQA is conducting audits based on identified risk, including audits conducted as a result of complaints. ASQA will provide the RTO with a compliance audit report, and if non-compliance is identified ASQA can either:
- issue the RTO with a written direction, requiring you to take a certain action
- issue the RTO with a ‘Notice of intent to impose administrative sanction’, or
- in exceptional circumstances, impose one or more sanctions on the RTO without prior notice.
If ASQA identifies highly concerning non-compliances at audit the RTO can now be issued with a ‘Notice of intent to impose administrative sanction’. RTOs will then have up to 20 working days to respond to the notice and submit any supporting evidence before a decision is made.
This is also a real game changer. The current process allows an RTO the chance to respond to non-compliances and provide evidence of compliance after an audit. At that stage if ASQA was still not satisfied they would then issue the RTO with a ‘Notice of intent to impose administrative sanction’ allowing the RTO an additional 20 days. RTOs will now have significantly less time to rectify their non-compliances following a non-compliant audit outcome. Instead of having in some cases a few months to rectify non-compliances RTOs may now only have a few weeks at best.
It is not all doom and gloom though. If ASQA identifies non-compliances at audit that are deemed to be not of a serious nature, ASQA may now issue the RTO with a written direction to address the non-compliances within a specified period and to maintain evidence of doing so. Is such cases RTOs will not be required to respond or provide evidence of rectification to ASQA. This is a good step towards less red tape and regulation.
- ASQA is developing a new audit model [WATCH THIS SPACE]
ASQA has announced that it is currently in the process of reviewing its approach to auditing RTOs and is developing a more risk-based approach that will focus more on student experience and the actual practices and behaviours of RTOs. We also suspect that the quality and sufficiency of both learning and assessment material will be a focus for the regulator moving forward. The team at Audit Express have called on this for quite some time now and we welcome the regulators efforts to take a more risk-based approach to its regulation of RTOs.Keep your eyes out over the next month as more information regarding the new audit model will be published and ASQA will start to implement their new model later this year, with full implementation by early 2017.
For more information on changes to the ASQA Audit Process you might like to check out the latest ASQA Update.
The best way to make sure your RTO is Audit Ready and that it meets the requirement for RTOs to submit an annual declaration of compliance with the Standards for RTOs is to undertake an annual internal audit of your RTO with the support of a reputable independent internal auditor.
It is crucial that you are fully aware of your RTOs strengths, weaknesses and areas for improvement. Most importantly you should be fully aware of the quality of the training products across your full scope of registration.
If you need help to make sure your RTO is compliant and Audit Ready get in touch with the team at Audit Express.