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Can you learn faster than other RTOs to ensure that you remain compliant and competitive?
Is your RTO a learning organisation? Are you ready to respond to changing needs and external challenges and remain competitive? Karash (2002) stated that a ‘learning organisation’ is one in which people at all levels, individually and collectively, are continually increasing their capacity to produce results they really care about’.
Earlier this year we wrote about using the ‘ good for business’ approach to RTO management to address regulatory changes in the VET sector. Since then ASQA has been implementing their risk based auditing, and has announced the introduction of ‘a more proactive audit approach (ASQA Fact Sheet, August 2016). We will recap on the changes and consider how a learning organisation would respond!
Why not take this opportunity to reflect on what you are doing and identify changes you need to make to step up!
Risk Based Auditing
ASQA’s is shifting to a risk based approach to regulation of the sector. Providers will be given a profile that is influenced by a number of factors including their audit and complaints history, compliance with data provision requirements and other interactions with ASQA including submission of the annual declaration of compliance. However, the frequency of audit will not be based solely on your RTO profile. ASQA will gather information using a range of methods and will consider both systemic and provider risk when determining the need for auditing and intervention.
‘ASQA’s risk-based approach to regulation means that a provider with a history of good performance, that does not exhibit concerning or unusual behaviour, is less likely to experience regulatory intervention by ASQA than a provider with a poor performance history particularly where ongoing concerns are detected or reported (ASQA Regulatory Risk Framework, April 2016). The frequency or cycle of audit is likely to change for RTOs as the regulator moves away from a transactional model of audit to this new risk based approach. The cycle of audit for some RTOs has already shifted to 7 years and ASQA has reduced the hoops to jump through for some applications e.g. add to scope.
ASQA’s approach to audit will also change. Auditors will focus on the key phases of the student experience. They will request evidence to demonstrate your RTO’s:
- marketing, recruitment and enrolment practices,
- support for students,
- approach to training and assessment and,
- processes for determining that a student has completed their studies.
The Standards will still be referenced but this approach should be more conducive to you telling ‘ your story’. The approach will also result in more timely and effective regulatory actions. This new approach is being rolled out from October – December 2016 – we will keep an eye on what is happening and bring our insights to you along the way.
Are you a reactive or a proactive RTO?
While the changes may seem encouraging, we believe that some RTOs may be caught out. Why? Unfortunately, we see many RTOs that take a ‘reactive’ approach to compliance. This means that they respond to issues only as they arise. When there is no big audit on the horizon their attention to compliance is only cursory. These RTOs are not learning organisations and go through the motions without attempting to continuously improve their practices.
This is what we often see. About 6 – 12 months before an audit the RTO establishes an audit committee to ‘get ready’ for the audit. What follows? Policies are rewritten to catch up with changes in practice and the student management system is audited and brought up to date. Assessments are validated and meetings minutes are updated ( or written and backdated!). Trainers and students are taught how to respond to auditor’s questions. By the time the audit comes around the RTO gives the appearance of being on top of compliance. Once the audit is over everyone relaxes and return to old habits.
How will this ‘reactive’ RTO cope within a risk based system? Even if the provider profile has been stable and generally compliant a change in systemic focus by the regulator or a problem/complaint reported to ASQA can alter the profile. These changes may result in an impromptu audit. Will this RTO be ready for a spot check audit? Unlikely!
How will you adapt?
For these ‘reactive’ RTOs, coping with regulatory changes will require a change in attitude to compliance management. We have outlined how a learning organisation would approach the need for such change.
A Learning Organisation would:
- Acknowledge that adapting to the new regulatory approach is essential to allow a sustainable competitive advantage!
- Work as a team to establish a shared vision and strategic goals for the organisation.
- Take a proactive and ‘good for business’ approach to RTO and compliance management.
- Prepare a shared plan for implementation of the revised vision and strategic and operational goals
- Treat this like a new, high priority project, not something to be done “when there is time.”
- Involve people at all levels in decision making by including both teaching and professional staff
- Use the change as a learning opportunity for the whole organisation.
- Create an atmosphere where all staff can question decisions.
- Learn from the change experience and use new and innovative approaches to improve processes for compliance and business management.
- Make sure the change process is adequately resourced. (Is there is adequate time for change? Are their sufficient people to implement change and is professional development available to enable the people to do their jobs?)
- Ensure that leaders are equipped to support change and build team.
- Use a continuous improvement approach to change.
- Evaluate the success of change, and address problems as they arise.
- Involve a range of stakeholders including clients in the change process.
- Document the change process so the model can be used again.
Ask The Learning Community for Help
We have worked with a number of RTOs to implement a proactive and continuous improvement approach to compliance and risk management. We are also equipped to help you build your team, review your vision and strategic goals and align compliance and risk activities with the key business functions of your organisation.
If you would like help contact us on firstname.lastname@example.org and we can chat about the best solutions for you and your Registered Training Organisation or visit our products page for lots of helpful resources.
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