Why do RTOs struggle with compliance?

Marlene Liontis, eWorks Accredited Consultant

Sarah Phillips is a Senior Educator VET Assessment Specialist at Chisholm Online. She specialises in developing assessments for the online environment and has a background in e-learning that stretches for ten years. If you’re struggling to tick all of the compliance boxes at your registered training organisation (RTO), Sarah’s blog highlights a topic that trips up so many people.

Yes, many RTOs are non-compliant

It is not uncommon for an RTO to be found non-compliant in what was previously Standard 15 of the Standards for NVR RTOs 2012 when experiencing an audit. Standard One now replaces much of what was this standard prior to 2015. In fact from October 2013 to March 2014, 78% of all existing RTOs were found non-compliant in their initial audit for Standard 15 – the elements that underpin quality in training and assessment. This can be an even greater risk when delivering courses online, because RTO staff may believe that near enough is good enough when addressing the components of a unit of competency and training package.

Common non-compliances

Here is a list of common non-compliances when dealing with assessment:

  • over or under assessing
  • failure to fully address the requirements or components of those requirements
  • addressing skills requirements as knowledge
  • incorrect mapping to criteria and required knowledge and skills
  • using language of the unit of competency for assessment
  • unclear instruction given to students
  • open questions that could result in the student not covering the criteria
  • tasks not sufficient to cover the requirements of the unit of competency
  • observable tasks passed off as knowledge or non-observable activities
  • assessments over or under the required AQF level
  • risk of trainer bias
  • failure to address implicit and explicit requirements.

This is a long list, and ensuring all these issues are avoided takes time and good processes to be in place. However, it also takes great attention to detail, and this is often where RTOs are let down by their assessments. This is where it can be important to unpack your unit of competency before you embark on writing your assessments.

Why can it be so hard?

Most training packages require you to assess students within the context of the industry, that is within a simulated environment or within the workplace. This can have huge implications for those RTOs delivering in the online environment. Just because it is inconvenient for your RTO to deliver in a simulated or real workplace, doesn’t mean you don’t have to do it. The main factors in all of this are the observable skills over time and real-time assessments and knowledge, demonstrated in context and applied.

Getting your evidence right

I have had many RTOs ask me how much evidence is enough? I give the same answer that an auditor would – sufficient. We must comply with the Rules of Evidence and Principles of Assessment when writing our assessments, and fortunately the 2015 standards explicitly explain this to us. However, it is not difficult to identify how much evidence is sufficient if you look into the language of the unit of competency and, in particular, the performance criteria, skills and knowledge. The identification of action words, multiple items and occurrences, plurals and other implicit requirements can help to make sure you write assessments that fully cover the criteria – and provide enough information to the students for them to provide the evidence you require to find them competent in the unit.

Here is an example

Share personal experiences and knowledge with the person being mentored according to agreed objectives.

When deconstructing the literal requirements of these performance criteria, we can identify the active verb (Share), the recipient or participant (person being mentored), the abstract nouns (experience and knowledge) and the condition of demonstration (according to agreed objectives).

This criteria has a number of components that need to be included when writing an appropriate assessment for the student to undertake. It clearly identifies resources required for the student to be able to complete the task, those being access to a ‘person being mentored’ and access to ‘agreed objectives’. To sufficiently cover this criteria, you need to provide a contextual environment for this activity to occur.

How things can go wrong online

Although it may be tempting in an online environment, it is not adequate for an assessment to simply ask:

How would you share personal experiences and knowledge with the person being mentored according to agreed objectives?

Firstly, the student hasn’t actually done the task, and secondly, it has ambiguous components. It can be considered measurable to assess one’s ability to share something with another person according to a set of rules, however the abstract nouns (experience and knowledge) create a facet that is immeasurable within this criteria. What does experience and knowledge actually look like? Therefore the criteria are ambiguous and must be interpreted by the writer to create a benchmark for the student to provide measurable evidence. You also need to make it explicit that the student is required to share both knowledge and experience as one or the other is not enough to fulfil the criteria.

Then how should you do it?

This criteria would be better evidenced through a project where a student is required to engage in a session with a person being mentored. It would also be ideal to group this criteria with others that help to provide context to the situation. You can see that a single performance criterion can hold a large amount of detail to be covered, and attention to detail is necessary to ensure your RTO is found compliant at audit.

Are you watching your language?

Although the standards have changed for those entering RTO land, and they are changing in April 2015 for those already in it, the simple rule of watching your language still and always applies. Indeed watching your language is the most important part of complying with VET legislation and all the supporting documents included within its implementation. Make sure you have good writers (or at least proofreaders) who understand language and can take the time to make sure your application is done right. It will cost you less, both in time and in your RTO registration, to do it right the first time.

Sarah would love to hear your thoughts on this article. Follow her on LinkedIn or Twitter for more advice about everything VET. And if you’re struggling to get your online content compliant eWorks has a team of instructional designers that can help.