The Training Accreditation Council (the Council) has a strong commitment to reducing the regulatory burden for providers that consistently demonstrate compliance with the requirements for registered training organisations (RTOs) in Western Australia. The introduction of the Council's Compliance Recognition Program (CR Program) is designed to provide RTOs that consistently demonstrate compliance, a degree of flexibility by removing the requirement for RTOs to submit applications or fees to the Council for amendment activity to their scope of registration.
The CR Program is premised on the basis that the RTO has undertaken an internal verification process to determine that training products meet compliance with the Standards for Registered Training Organisations (RTOs) 2015 (Standards for RTOs), Australian Qualifications Framework (AQF) and requirements of registration as an RTO under the Vocational Education and Training Act 1996. The Council retains the overall authority to approve the amendment.
The granting of participation in the CR Program by the Council does not indicate or imply that the RTO is of a higher standard or of a lower risk than other RTOs. The Council does not consider risk ratings when identifying RTOs eligible for participation in the CR Program.
Terms and Conditions
To participate in the CR Program, the Council will invite RTOs that meet the eligibility criteria. Should an invited RTO wish to be part of the CR Program they will be required to agree to the Terms and Conditions set out in this document.
Prior to an invitation being offered to an RTO to participate in the CR Program, RTOs are required to meet the following criteria:
- have been registered for a minimum of five (5) years;
- registration has been renewed by the Council with no non-compliances identified at audit (this does not include compliance demonstrated through rectification actions); or
- the RTO has had its registration renewed by the Council with minor non-compliances and has demonstrated full compliance at subsequent audits; and
- there are no regulatory concerns or regulatory actions being taken by the Council against the RTO.
Participation in the CR Program will be for a period of up to five years, subject to ongoing satisfactory performance and compliance with the Standards for RTOs, AQF and requirements of registration as an RTO under the Vocational Education and Training Act 1996, and will be aligned to an RTOs renewal of registration.
The Council maintains discretion in selecting RTOs to participate in the CR Program and may remove participation at any time. Participation in the CR Program will be reviewed by the Council annually based on the RTOs submission of an annual return, internal audit report and any other regulatory intelligence requested by the Council.
Nominated RTO representative requirements
The RTOs legally responsible officer or a person that holds a senior position within the organisation is required to act as the nominated representative to liaise with the Council regarding participation in the CR Program. The nominated representative is required to provide any information requested by the Council in relation to the RTO's participation in the CR Program.
The legally responsible officer must notify the Council of any changes to the nominated representative within 30 working days of the change occurring.
Implementation of a Quality Management System for the CR Program
As part of participation in the CR Program, RTOs are required to implement a documented quality management system (QMS). A QMS demonstrates how an RTO implements, monitors and reviews the system specifically in relation to the verification conducted as part of the CR Program. It also includes the RTO's CR Program policies, procedures, guidelines, outlines of roles and responsibilities, forms, templates and any other documentation the RTO deems relevant in quality assuring its participation in the CR Program.
While individual RTOs determine the design of the QMS, at a minimum, the system must incorporate information outlined at the following document:
QMS minimum requirements.
Internal verification process and notification to the Council
RTOs are required to undertake an internal verification process to determine that training products meet compliance with the Standards for RTOs, Australian Qualifications Framework (AQF) and requirements of registration as an RTO under the Vocational Education and Training Act 1996.
Prior to notifying the Council of verification outcomes, the RTO must:
- verify that each qualification, unit of competency or accredited course the RTO intends to deliver and assess is compliant against the Standards for RTOs and the AQF;
- ensure the determination of compliance with the Standards for RTOs and the AQF is made by a person or persons that hold the competency requirements for auditors as outlined in Schedule 1 of the Standards for VET Regulators 2015; and
- submit a notification to the Council (in a form approved by TAC) for each qualification, unit of competency or accredited course the RTO intends to add to its scope of registration.
Note that where your RTO may be subject to additional requirements placed on your organisation by other regulators, government agencies or stakeholders, you are required to ensure those requirements are met prior to notifying the Council of the amendment activity.
External audit process
RTOs participating in the CR Program agree to be audited by an auditor from the Council's Auditor Panel to determine compliance with the terms and conditions of the program as and when required by the Council. All costs relating to the external audit including travel and accommodation are the responsibility of the RTO.
The scope and duration of the audit will be determined by the Council and may include:
- undertaking a review of the RTOs compliance with the requirements of the CR Program;
- validation of decisions made by the RTO in relation to the CR Program; and
- ensuring the documented quality management system (QMS) enables the organisation to undertake and implement the requirements of the CR Program including undertaking effective annual internal reviews.
The Council uses a range of indicators to determine if and when an audit of the terms and conditions of the CR Program is warranted, including, but not limited to:
- significant change in the type and number of amendments to scope, particularly changes to new industry sectors/vocational areas;
- advice or intelligence from other agencies and regulators;
- complaints received regarding the quality of training and/or marketing; and
- regulatory action by the Council in response to non-compliances identified through audit activity.
The audit process includes the following stages:
a) Planning for audit:
- Initial contact made and service agreement confirmed with auditor
- Review of participation in the CR Program and identification of audit sample
- Request submission of pre-audit evidence
- Scheduling of audit, meetings and interviews.
b) Preparing for audit:
- Populate audit report and tool templates
- Consider submitted pre-audit evidence
- Confirm audit arrangements.
c) Conduct of the audit:
- Conduct opening meeting
- Gather and review evidence
- Review of quality assurance system related to participation in CR Program
- Validate the decisions made in in the verification process undertaken by the participating RTO through auditing a sample of verification decisions
- Review of supporting evidence pertaining to the audit sample
- Consider findings
- Conduct exit meeting.
d) Reporting the findings of the audit:
- Prepare draft report
- Draft report reviewed by the participant identifying any errors of fact
- Initial audit report, adjusted where necessary in response to participant's feedback, submitted to participant and the Council by the nominated auditor
- 20 days rectification period is available to enable the participant to address identified weaknesses or inconsistencies and to submit evidence of rectification
- Submission of Final Report to participant and the Council.
It is estimated the duration of audit planning, preparation and report writing may take between 0.5 to three (3) days, and the duration of an audit may take between one (1) to three (3) days.
Additional audits may be required as a result of compliance rectification actions and/or subject to concerns regarding an RTOs performance against the requirements of the CR Program and Standards for RTOs, AQF and requirements of registration as an RTO under the Vocational Education and Training Act 1996.
In relation to the QMS and its implementation, the audit findings will include a judgement as to the participant's verification capability. It will indicate how effectively the participant uses review information to understand its performance and bring about improvement in relation to its participation in the CR Program.
RTOs participating in the CR Program are required to report to the Council. The Council will determine reporting requirements and timeframes. At a minimum, RTOs will be required to report at least annually in relation to the RTOs QMS of the CR Program, and submit the following reports to the Council:
- an annual self-assessment audit report submitted each calendar year (at a date yet to be determined); and
- an annual return to be submitted using the TAC Annual Return Report template (at a date yet to be determined).
Failure to submit reports may result in an RTOs participation in the CR Program being removed.
If an RTO wishes to advertise or promote its participation in the CR Program the following terminology must be used:
'Approved participant in the Training Accreditation Council Compliance Recognition Program'
When using this terminology RTOs must refer to the CR Program page on the Council website. In written documentation this reference is to include the URL, and in electronic documentation via a live link. No other terminology is to be used by RTOs to promote participation in the CR Program.
Cancellation of Participation in the CR Program
The Council maintains discretion in selecting RTOs to participate in the CR Program and may remove participation at any time.
Training Products Exempt from the CR Program
The CR Program does not extend to units of competency, qualifications or accredited courses that lead to a licensed or regulatory outcome, or originate from the TAE10 Training and Education Training Package, or its successor.
RTOs who wish to deliver exempted units of competency, qualification or accredited course are required to apply directly to the Council with the associated fee.
RTOs will be advised of any training products on their existing scope of registration that are excluded from the CR Program prior to acceptance.
Responsibility of the Council in managing the CR Program
On receipt of a verification notification from an RTO participating in the CR Program, the Council, under Regulation 17 (3)(b) of the Vocational Education and Training (General) Regulations 2009, will on its own initiative, amend the RTOs scope of registration and the registration on the National Register located at www.training.gov.au. In most instances the Council will approve and update the National Register within 1-2 business days of receipt of notification.
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